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transferee of the property from the due date of the estate tax
return.
Unless otherwise noted, section references are to the
applicable version of the Internal Revenue Code, and Rule
references are to the Tax Court Rules of Practice and Procedure.
Amounts are rounded to the nearest dollar.
Background
The parties submitted this case fully stipulated pursuant to
Rule 122. The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time the petition
was filed, petitioner resided in Palm Beach Gardens, Florida.
Petitioner is the daughter of Mary Kabbash (decedent), and
she is the sister of William Kabbash, Samuel Kabbash, and Joyce
Samaha. In early 1989, decedent gave William Kabbash a general
power of attorney to make gifts to her children on her behalf.
As power of attorney for decedent, William Kabbash gifted
the following to petitioner:
Date Amount
Aug. 27, 1989 $ 10,000
Sept. 28, 1989 10,000
Nov. 10, 1989 150,000
Petitioner received an additional $115,000 from decedent or the
estate from January 1989 to September 1992.
Decedent died on November 15, 1989. At the time of her
death, decedent had a will that controlled the disposition of her
assets and that named William Kabbash and Samuel Kabbash as
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