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When decedent died, the revocable trust held assets worth
$88,659,780. The trustees distributed those assets to the
marital trust.
The Circuit Court of Cook County, Probate Division, admitted
decedent’s will to probate on July 10, 1990. The value of the
probate estate was $760,253 on decedent’s date of death. The
personal effects which decedent bequeathed to Ann Lurie were
worth $12,470 when he died. The value of the residue of the
probate estate was $747,783 on decedent’s date of death. The
funeral expenses and miscellaneous administration expenses were
paid from the residue of the probate estate. The probate estate
distributed the residue to the revocable trust. During his
lifetime, decedent made taxable gifts which fully absorbed the
unified credit. As a result, the nonmarital residuary trust was
not formed, and the revocable trust distributed all of its assets
to the marital trust.
The estate reported on its Federal estate tax return a gross
estate of $91,712,318, deductions totaling $91,712,318 (marital
deduction of $91,682,908 and other deductions of $29,410), and a
taxable estate of zero. Decedent’s estate did not include the
value of the notice trusts in the gross estate on its Federal
estate tax return.
Respondent determined that the value of the notice trusts is
included in decedent’s gross estate. Respondent also determined
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