125 T.C. No. 11
UNITED STATES TAX COURT
ESTATE OF DORIS F. KAHN, DECEASED, LASALLE BANK, N.A., TRUSTEE
AND EXECUTOR, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 12551-04. Filed November 17, 2005.
The estate filed Form 706, U.S. Estate (and
Generation-Skipping Transfer) Tax Return (“estate tax
return”). R issued a notice of deficiency that inter
alia asserted increases to the gross estate by
disallowing a reduction in value of P’s individual
retirement accounts (IRAs) by the expected Federal
income tax liability resulting from the distribution of
the IRAs’ assets to the beneficiaries under sec.
408(d)(1), I.R.C. (income tax liability). This matter
is before us on P’s motion for partial summary judgment
under Rule 121(a), contesting R’s disallowance of the
reduction in the value of the IRAs. R filed a cross-
motion for summary judgment in response to P’s motion.
Held: In computing the gross estate value, the
value of the assets held in the IRAs is not reduced by
the anticipated income tax liability following the
Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011