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qualified terminable interest property (QTIP) trust established
by decedent’s predeceased first wife and that is includable in
decedent’s gross estate pursuant to section 2044; (3) the amount,
if any, of net taxable gifts arising with respect to the 1995
assignment to decedent’s children of a promissory note; (4) the
amount, if any, of decedent’s unreported taxable gifts in 1993
and 1989; and (5) the amount deductible under section 2053(a)(2)
as administration expenses of the estate.1
FINDINGS OF FACT
The parties have stipulated some facts, which we
incorporate, along with the associated exhibits, into our
findings.
Decedent
Lewis A. Bailey (decedent) died on December 18, 1995. His
domicile at death was in Garland County, Arkansas. When the
petition was filed, the executrix resided in Hot Springs,
Arkansas.
C&L Bailey
In 1985, decedent and his wife, Ethel C. Bailey (Ethel),
incorporated C&L Bailey, an Arkansas nonpublicly traded
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect at the date of decedent’s
death, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
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