- 4 - Background In a memorandum of law in support of its objection to respondent’s motion for partial summary judgment, the estate states that it agrees, with limited exceptions, to the statement of facts contained in respondent’s memorandum of law in support of the motion for partial summary judgment. The following factual summary is based on the undisputed portions of respondent’s statement of facts, the parties’ stipulations, the estate’s admissions, the pleadings, and an affidavit produced by respondent with accompanying documents, to which the estate has not objected. This factual summary is set forth solely for purposes of deciding the motion for partial summary judgment; it does not constitute findings of fact. See Sundstrand Corp. v. Commissioner, 98 T.C. 518, 520 (1992), affd. 17 F.3d 965 (7th Cir. 1994). Decedent Decedent was president and primary stockholder of National Fruit Product Co., Inc. (National Fruit), a closely held Virginia corporation engaged in the manufacture of applesauce, apple juice, and other fruit products. On July 29, 1993, decedent died. His domicile at death was in Winchester, Virginia. When the petition was filed, the executor’s legal residence was in Winchester, Virginia.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