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.Page: 1 2 3 4 5 6 7 8 9 10 Next
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