- 2 - 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.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