Estate of Paul C. Gribauskas - Page 2




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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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