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Anne Marie Mazzu and Lewis Cohn, for petitioner.
Joseph J. Boylan, for respondent.
MEMORANDUM OPINION
NIMS, Judge: Respondent determined a Federal estate tax
deficiency in the amount of $147,800 with respect to the estate
of David Katz (the estate). The issue for decision is whether
the estate is liable for a deficiency in estate tax because of
bequests disclaimed by Sarah Katz.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect during the relevant periods,
and all Rule references are to the Tax Court Rules of Practice
and Procedure.
Background
This case was submitted fully stipulated pursuant to Rule
122, and the facts are so found. The stipulations of the
parties, with accompanying exhibits, are incorporated herein by
this reference.
David Katz (decedent) was a resident of the State of New
Jersey when he died testate in that State on September 23, 1998.
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