T.C. Memo. 2005-247
UNITED STATES TAX COURT
ESTATE OF MARIE A. MANIGLIA, DECEASED, JOSEPH S. MANIGLIA,
EXECUTOR, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 20141-03. Filed October 26, 2005.
Paul J. Dee, Jr., and Jueun Chung, for petitioner.
Michael R. Fiore, for respondent.
MEMORANDUM OPINION
WELLS, Judge: Respondent determined a $764,472 deficiency
in the estate tax of the Estate of Marie A. Maniglia (the
decedent). The issue we must decide is whether the entire value
of certain real property or only 50 percent of the value of that
property is properly includable in the decedent’s gross estate.
All section references are to the Internal Revenue Code, as
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