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(2) 1,832.357 shares, Marriott International,
Inc.;
(3) 6,904.323 shares, PECO Energy;
(4) 776.5432 shares, PSE&G, Inc.; and
(5) 1,800 shares, Sempra Energy.
In addition, I hereby renounce and disclaim
irrevocably and forever any right, title and interest
in and to the trust created for my benefit pursuant to
Article THIRD of my husband’s Will.
On December 28, 1999, the estate filed Form 706, United
States Estate (and Generation-Skipping Transfer) Tax Return.
On November 1, 2002, respondent issued to the estate a
statutory notice of deficiency.
Discussion
Section 2001(a) imposes a tax on “the transfer of the
taxable estate of every decedent who is a citizen or resident of
the United States.” Section 2031(a) provides that “The value of
the gross estate of the decedent shall be determined by including
to the extent provided for in this part, the value at the time of
his death of all property, real or personal, tangible or
intangible, wherever situated.”
Section 2056(a) provides for a deduction from the gross
estate of a decedent for the value of property that passes from
the decedent to the surviving spouse.
Section 2046 provides that disclaimers of property interests
passing upon death are treated as provided in section 2518.
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Last modified: May 25, 2011