Estate of Margot Stewart, Deceased, Brandon Stewart, Executor - Page 2

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          whether the value of that property should be included in                    
          decedent’s estate pursuant to section 2036,1 and whether                    
          decedent’s estate is entitled to deductions relating to property            
          taxes and claims against the estate.                                        
                                  FINDINGS OF FACT                                    
               On July 10, 1989, Margot Stewart (decedent) executed a deed            
          that transferred to Brandon Stewart, her son, real property                 
          located in East Hampton, New York (the East Hampton property).              
          As a result of the transfer, decedent and Mr. Stewart owned the             
          East Hampton property as joint tenants with rights of                       
          survivorship.  Decedent and Mr. Stewart agreed to share the                 
          income and expenses relating to the East Hampton property.                  
          Decedent also owned real property located at 160 East 61st                  
          Street, New York, New York (the 61st Street property).  Decedent            
          and Mr. Stewart resided on the first two floors of the 61st                 
          Street property.  Beginning on October 1, 1999, decedent leased             
          the remaining three floors of the 61st Street property to                   
          Financial Solutions, Ltd., an unrelated third party, for $9,000             
          per month.                                                                  
               On May 9, 2000, decedent executed a deed that transferred to           
          Mr. Stewart a 49-percent interest in the 61st Street property.              

               1  Unless otherwise indicated, all section references are to           
          the Internal Revenue Code in effect for the year in issue, and              
          all Rule references are to the Tax Court Rules of Practice and              

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