121 T.C. No. 4
UNITED STATES TAX COURT
ESTATE OF LEONA ENGELMAN, DECEASED, PEGGY D. MATTSON, EXECUTOR,
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
thereof.
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