Estate of Marcia P. Hoffman, deceased, Elisabeth Hoffman, Personal Representative - Page 2




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          Whether guaranteed distributions under a marital settlement                 
          agreement survived decedent’s death and are includable in her               
          gross estate under section 2031;2 and (2) the fair market value             
          of certain property interests held by decedent at the time of her           
          death.                                                                      
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts, stipulation of settled issues, and the            
          attached exhibits are incorporated herein by this reference.                
               Marcia P. Hoffman (decedent) died testate on February 18,              
          1994.  The beneficiaries of her estate are her children and                 
          grandchildren.  At the time of her death, decedent resided in               
          Pinellas County, Florida.  A Federal estate tax return was filed            
          on behalf of decedent’s estate on February 21, 1995, wherein the            
          alternate valuation date, August 18, 1994, was selected.  Donald            
          F. Chamberlain, Sr. (Mr. Chamberlain), and Elisabeth Hoffman (Ms.           
          Hoffman), decedent’s daughter, were listed as the executors on              
          decedent’s estate tax return.  Respondent sent notices of                   
          deficiency to both Mr. Chamberlain and Ms. Hoffman.  In the                 



               1(...continued)                                                        
          adjustments.  The remaining adjustments proposed by respondent              
          remain disputed by the estate and are addressed in this opinion.            
               2Unless otherwise indicated, all section references are to             
          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.                                                     





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