- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011