Estate of Eleanor T.R. Trotter - Page 2

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                                 MEMORANDUM OPINION                                   
               NIMS, Judge:  Respondent determined a Federal estate tax               
          deficiency in the amount of $48,750 for the estate of Eleanor               
          T.R. Trotter (the estate).  The issues for decision are whether,            
          pursuant to section 2036(a), the gross estate of Eleanor T.R.               
          Trotter (decedent) includes the value of a residence transferred            
          to an irrevocable trust and, if so, the proper value of the                 
          property for estate tax purposes.                                           
               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.                                            
               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 Little Rock,                    
          Arkansas, when she died testate in that State on January 31,                
          1996.  Her will was subsequently admitted to probate in the                 
          Probate Court of Pulaski County, Arkansas, Fourth Division.                 
          William F. Rector, Jr., and Ann Rector Lewis were named co-                 
          executors of the estate and likewise provided a mailing address             
          of Little Rock, Arkansas, at the time the petition in this case             
          was filed.                                                                  

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