T.C. Memo. 2006-215
UNITED STATES TAX COURT
ESTATE OF SARAH M. DAVENPORT, DECEASED, RICHARD DAVENPORT,
EXECUTOR, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 16060-04. Filed October 5, 2006.
D died on Oct. 31, 2000, and a Federal estate tax
return was thereafter filed on behalf of her estate.
Held: Two annuities payable under a settlement
agreement are includable in the gross estate pursuant
to sec. 2033, I.R.C.
Held, further, for purposes of inclusion in the
gross estate, the annuities are to be valued under sec.
7520, I.R.C., in accordance with the actuarial
valuation methodology of sec. 20.2031-7(d), Estate Tax
Regs.
Held, further, under the circumstances present in
this case, expenditures incurred for a funeral luncheon
are not properly deductible as funeral expenses under
sec. 2053(a)(1), I.R.C.
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Last modified: May 25, 2011