Estate of Ida Abraham, Deceased, Donna M. Cawley, and Diana A. Slater, Administratrixes - Page 2

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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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