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as the measuring life, and “Donna Weiss-Davenport and Richard
Davenport as Co-Conservators of Sara [sic] Maria Davenport” as
the payee for benefit checks. Likewise, a single premium
nonparticipating immediate annuity was issued by Safeco Life
Insurance Company, with Safeco Assigned Benefits Service Company
designated as the owner, decedent as the annuitant, and her
parents in their role as “Co-Conservators” as the payee.
Consistent with the settlement agreement, both annuities provided
for $2,500 monthly payments commencing November 15, 1991,
increasing at a compounded 5 percent annually, for a minimum of
360 payments. Both annuities also indicated that decedent’s
estate would be the beneficiary in the event of her death.
As noted above, decedent died on October 31, 2000, due to
septic, acute renal failure and cardiogenic shock. A Form 706,
United States Estate (and Generation-Skipping Transfer) Tax
Return, was filed on her behalf on July 31, 2001. The Form 706
reported a total gross estate of $414,937.05, total deductions of
$51,253.19, a resultant taxable estate of $363,683.86, and a
gross estate tax of $109,452.51. After application of the
unified credit, no tax was reported as due.
The principal assets included in the gross estate were
mutual fund interests and U.S. Treasury bills. Schedule I,
Annuities, listed the Allstate and Safeco annuities but reported
that the respective includable value of each at the date of death
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