T.C. Memo. 2001-250 UNITED STATES TAX COURT ESTATE OF ELEANOR T.R. TROTTER, DECEASED, WILLIAM F. RECTOR, JR., AND ANN RECTOR LEWIS, CO-EXECUTORS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 288-00. Filed September 21, 2001. In 1993, D gratuitously transferred her residence to an irrevocable trust, naming her daughter as trustee and her grandchildren as beneficiaries. D then continued to occupy the residence without payment of rent until her death in 1996. Held: There existed an implied understanding that D would retain possession and enjoyment of the residence such that the property is includable in her gross estate under sec. 2036(a)(1), I.R.C. Held, further, the value of the residence for purposes of inclusion in the gross estate is $125,000. H. Lawrence Yancey, for petitioner. Elizabeth Downs, for respondent.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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