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under section 2036.1 Respondent concedes that decedent received
$320,000 in connection with the transfer of certain limited
partnership interests to her daughters, an amount which
constitutes consideration within the meaning of section 2043.
Additionally, respondent concedes adjustments made in the notice
of deficiency for adjusted taxable gifts in the amount of $71,195
and an aggregate gift tax payable in the amount of $29,142.
Because of respondent’s concessions, a Rule 155 computation will
be necessary.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time of filing the
petition, the administratrixes, Donna M. Cawley and Diana A.
Slater, resided in Massachusetts.
Background
Decedent and her husband, Nicholas Abraham (Mr. Abraham,
Sr.), had four children: Nicholas A. Abraham, Richard Abraham,
Donna Cawley, and Diana Slater. Mr. Abraham, Sr., died on June
5, 1991, leaving significant assets to his wife. Of his nearly
$7 million estate, $4,168,885.37 is reported as passing to
1All section references are to the Internal Revenue Code in
effect as of the date of decedent’s death, and unless otherwise
indicated all Rule references are to the Tax Court Rules of
Practice and Procedure.
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