Estate of Sarah E. Greve, deceased, Charles E. Greve & David R. Greve, Co-Executors - Page 2

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          power of appointment at the time of her death includible in                 
          decedent’s gross estate under section 2041(a)(1)?1  We hold that            
          it is.                                                                      
               (2) Is certain property with respect to which decedent had a           
          power of appointment at the time of her death includible in                 
          decedent’s gross estate under section 2041(a)(2)?  We hold that             
          it is.                                                                      
                                  FINDINGS OF FACT                                    
               Most of the facts have been stipulated and are so found.               
               Decedent was a resident of Pennsylvania at the time of her             
          death on December 27, 1998.                                                 
               At the time the petition was filed, Charles E. Greve and               
          David R. Greve, decedent’s sons and the co-executors (executors)            
          of the estate, had a mailing address in Pittsburgh, Pennsylvania.           
               On July 29, 1933, Sarah S. Wright (Ms. Wright), decedent’s             
          grandmother, executed her last will and testament (Ms. Wright’s             
          will) under which Ms. Wright, inter alia, created a testamentary            
          trust (testamentary trust).  Ms. Wright’s will provided in                  
          pertinent part as follows:                                                  
                    SECOND:  I give and bequeath all of the bonds and                 
               all of the corporate stocks which I may own at the time                




               1All section references are to the Internal Revenue Code               
          (Code) in effect on the date of decedent’s death.  All Rule                 
          references are to the Tax Court Rules of Practice and Procedure.            




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