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Recapitulation Gross estate Nonprobate Probate
Real estate $148,500 $148,500 -0-
Stocks & bonds 2,149,394 1,562,794 586,600
Mortgages, notes & cash 200,943 -0- 200,943
Ins. on the decedent's life 25,72025,720 -0-
Jointly owned property 519,141 519,141 -0-
Other misc. property 13,311 -0- 13,311
Gross estate 3,057,009 2,256,155 800,854
Funeral expenses 48,506 -0- 48,506
Additional admin. expenses39,000 -0- 39,000
Debts per return 5,899 -0- 5,899
Additional debts, unpaid17,576 -0- 17,576
income taxes
Federal estate tax 548,763 -0- 548,763
State death taxes 244,401 -0- 244,401
Ins. on the decedent's life 25,720-0- -0-
Bequest of rings to sister6,000 -0- 6,000
Bequest of household goods500 -0- 500
to executor
Total deductions 936,365 -0- 910,645
Net probate residue (109,791)
Trust assets 1,711,294
Net assets available for distribution 1,601,503
Charitable deduction (1/2 of net assets available)800,752
It is apparent that the principal difference between
respondent's computation of the allowable charitable
deduction and the estate's computation is that respondent
computed the charitable deduction after Federal estate tax
(viz, $548,763), State death taxes (viz, $244,401), and
additional debts (viz, $17,576) were deducted from the
assets available for distribution, whereas the estate
computed the charitable deduction before these amounts
were deducted.
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