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we cannot determine whether the Koesters were aware of the
provisions that the estate contends would have obviated the
incidence of estate tax. We are limited to considering the tax
ramifications based on the facts at hand, not what may have
otherwise occurred. Commissioner v. Natl. Alfalfa Dehydrating &
Milling Co., 417 U.S. 134, 148-49 (1974); Estate of La Sala v.
Commissioner, 71 T.C. 752, 764 (1979).
We hold that the $109,270 reported estate tax liability did
not result in a violation of decedent’s constitutional rights.
To reflect the foregoing,
A decision reflecting
no deficiency or overpayment
in estate tax will be entered.
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Last modified: May 25, 2011