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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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