Estate of Leona Engelman, Deceased, Peggy D. Mattson, Executor - Page 1

                                   121 T.C. No. 4                                     

                               UNITED STATES TAX COURT                                

                                    Petitioner v.                                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 4668-02.               Filed July 24, 2003.                 

                    In 1990, H and D, husband and wife, established a                 
               living trust.  The terms of the trust provided for an                  
               allocation of trust assets between two separate trusts,                
               Trust A and Trust B, upon the death of the first                       
               spouse.  Initially, all assets were to be placed in                    
               Trust A except to the extent disclaimed by the                         
               surviving spouse.  Disclaimed assets were to be placed                 
               in Trust B.  The surviving spouse was also granted a                   
               power of appointment effective at death over Trust A.                  
                    H died on Dec. 30, 1997.  On Feb. 5, 1998, D                      
               executed a document entitled “Power of Appointment”                    
               directing disposition of the Trust A corpus.  D died on                
               Mar. 6, 1998.  Thereafter, on May 11, 1998, the special                
               administrator of her estate executed a “Disclaimer” of                 
               D’s interest in Trust A assets valued at approximately                 
               $600,000 as of H’s earlier death.  Those assets were                   
               placed in Trust B and distributed to the beneficiaries                 

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