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OPINION
NIMS, Judge: Respondent determined a Federal estate tax
deficiency in the amount of $403,167 for the estate of Paul C.
Gribauskas (the estate). The sole issue for decision is whether
an interest held at his death by Paul C. Gribauskas (decedent),
in 18 annual installments of a lottery prize, must be valued for
estate tax purposes through application of the actuarial tables
prescribed under section 7520.
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
parties, with accompanying exhibits, are incorporated herein by
this reference. Decedent was a resident of West Simsbury,
Connecticut, when he died intestate in that State on June 4,
1994. His estate has since been administered by the probate
court for the District of Simsbury. Roy L. Gribauskas and Carol
Beauparlant, decedent’s siblings, are named co-executors of his
estate. At the time the petition in this case was filed, Roy
Gribauskas resided in Southington, Connecticut, and Carol
Beauparlant resided in Berlin, Connecticut.
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