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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.
Background
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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