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 thePage: 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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