118 T.C. No. 16
UNITED STATES TAX COURT
ESTATE OF ALDO H. FONTANA, DECEASED, RICHARD A. FONTANA AND JOAN
F. REBOTARRO, CO-EXECUTORS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 6635-00. Filed March 28, 2002.
A and D, husband and wife, owned all of L’s stock as
community property. D predeceased A, leaving 44.069 percent of
L’s stock to a trust over which A had a testamentary general
power of appointment. A also owned 50 percent of L’s stock
outright.
Held: For Federal estate tax valuation purposes, the stock
subject to A’s general power of appointment must be aggregated
with stock A owned outright.
Owen G. Fiore, John F. Ramsbacher, and Erin M. Wilms, for
petitioner.
G. Michelle Ferreira, for respondent.
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