T.C. Memo. 2004-112 UNITED STATES TAX COURT ESTATE OF ROSE B. POSNER, DECEASED, DAVID B. POSNER, PERSONAL REPRESENTATIVE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 12780-01. Filed May 10, 2004. Mark T. Willen and Peter E. Keith, for petitioner. C. Teddy Li, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION THORNTON, Judge: Respondent determined a $1,114,795 Federal estate tax deficiency with respect to the Estate of Rose B. Posner (the estate). The parties have resolved all issues raised in the notice of deficiency. The estate contends, however, that it is entitled to a $2,909,000 estate tax refund because certain marital trust property was erroneously included in the grossPage: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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