- 9 -
Less:
Funeral expenses 6,500
Debts 1,107
Mortgages and Liens 0
Specific bequest to spouse 573,216
Total allowable deductions 580,823
Taxable Estate 600,000
The total gross estate, as reflected on the estate’s Form
706, is $1,180,823. The estate claimed a total marital deduction
of $573,216,4 and total deductions of $580,823 from the gross
estate. The marital deduction was computed on Schedule M of the
estate’s Form 706, which primarily reflected the transfer of
assets, including securities, life insurance policies, and
individual retirement accounts, from the estate to the trust.
The estate reported a gross estate tax of $192,800 and
claimed the maximum unified credit against estate tax for 1997,
$192,800. Respondent determined that the claimed marital
deduction should be reduced by $564,862, resulting in a reduction
of the marital deduction from $573,216 to $8,354. Respondent
determined that the insurance payment of $8,354 was the only item
to qualify for the marital deduction because it was paid directly
to the surviving spouse. On September 13, 2001, Respondent
determined a deficiency in the estate’s Federal estate tax of
4Section Five of Part Four of Form 706 reports that the
testamentary trust received $586,670 from the estate.
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Last modified: May 25, 2011