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Held, further, the estate has failed to establish
its entitlement to a marital deduction in excess of
that allowed by respondent.
Robert B. Martin, Jr., for petitioner.
Ric D. Hulshoff, for respondent.
OPINION
NIMS, Judge: Respondent determined a Federal estate tax
deficiency in the amount of $144,980 with respect to the estate
of Hon Hing Fung (the estate). The issues for decision are:
(1) Whether a one-half interest owned by Hon Hing Fung
(decedent) in certain real property must be included in his gross
estate at its full value of $442,500, or whether the property may
be included at its net equity value after reduction for an
encumbrance in the amount of $324,974; and
(2) whether the estate is entitled to a marital deduction in
excess of that allowed by respondent.
Unless otherwise indicated, all section references are to
sections of the Internal Revenue Code in effect as of the date of
decedent’s death, and all Rule references are to the Tax Court
Rules of Practice and Procedure.
Background
This case was submitted fully stipulated pursuant to Rule
122, and the facts are so found. The stipulations of the
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