Estate of Augusta Porter Forbes - Page 2




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          tax valuation understatement.1  The issues for decision are:                
          (1) The fair market value at the date of decedent’s death of                
          undivided fractional interests in two parcels of real property              
          held in a qualified terminable interest property trust (QTIP                
          trust) in which decedent had an income interest for life.                   
          Subsumed in this issue is whether these undivided fractional                
          interests include interests in certain timber and pecan orchards            
          located on the parcels; and (2) whether petitioner is liable for            
          a penalty under section 6662(g).                                            
                                  FINDINGS OF FACT                                    
               The parties have stipulated some of the facts, which we                
          incorporate in our findings by this reference.                              
          Decedent                                                                    
               On December 26, 1993, Augusta Porter Forbes (decedent)                 
          died.  At the time of her death, she resided in Atlanta, Georgia.           
          Her estate was administered in Fulton County, Georgia.2                     




               1 Unless otherwise indicated, all section references are to            
          the Internal Revenue Code in effect at the date of decedent’s               
          death, and all Rule references are to the Tax Court Rules of                
          Practice and Procedure.                                                     
               2 The record does not conclusively establish the residence             
          or principal place of business of the executor of decedent’s                
          estate, Frederick W. Orr, Jr., as of the date the petition was              
          filed.  The petition provides only the executor’s mailing address           
          in care of a law firm in Atlanta, Georgia.  Decedent’s amended              
          Form 706, United States Estate (and Generation-Skipping Transfer)           
          Tax Return, signed Sept. 23, 1997, lists the executor’s address             
          as a Cashiers, N.C., post office box.                                       




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