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Edward C. Northwood, for petitioner.
Kevin M. Murphy, for respondent.
OPINION
VASQUEZ, Judge: Respondent determined a deficiency of
$105,3251 in the Federal estate tax of the Estate of Avrom A.
Silver (decedent). The issue for decision is whether the estate
of decedent, who was not a citizen of the United States and did
not reside in the United States, is entitled to a charitable
contribution deduction on the estate tax return (of more than the
amount allowed by respondent) pursuant to the Revised Protocol
Amending the Convention With Respect to Taxes on Income and
Capital, Mar. 17, 1995, U.S.-Can., S. Treaty Doc. 104-4 (1995)
(1995 Protocol).
Background
The parties submitted this case fully stipulated pursuant to
Rule 122.2 The stipulation of facts and the attached exhibits
are incorporated herein by this reference. At the time the
petition was filed, the mailing address for the estate was in
Toronto, Ontario, Canada.
1 Amounts are rounded to the nearest dollar.
2 All section references are to the Internal Revenue Code,
and all Rule references are to the Tax Court Rules of Practice
and Procedure.
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Last modified: May 25, 2011