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John D. Mabley, for petitioner.
John W. Stevens, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
WHERRY, Judge: Respondent determined a Federal estate tax
deficiency of $507,103 for the Estate of Sarah M. Davenport (the
estate). The issues for decision are:
(1) Whether two annuities payable under a settlement
agreement are includable in the gross estate for Federal tax
purposes pursuant to section 2033 or 2039;
(2) whether, in the event that the annuities are to be
included in the gross estate, they were properly valued by
respondent under section 7520; and
(3) whether the estate is entitled to a deduction for the
cost of a funeral luncheon pursuant to section 2053.1
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulations of the parties, with accompanying exhibits, are
incorporated herein by this reference. Sarah M. Davenport
(decedent) was a resident of the State of Michigan when she died
intestate in that State on October 31, 2000. Her estate has
1 Unless otherwise indicated, section references are to the
Internal Revenue Code (Code) in effect as of the date of death of
Sarah M. Davenport, and Rule references are to the Tax Court
Rules of Practice and Procedure.
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