- 5 - having received the prior written approval of the intended sale from my niece, WANDA RODGERSON. The trust was to operate for the longer of 10 years or the joint lives of John and Mary Tamulis,4 and upon termination, the remainder of the trust's assets was to pass to the Roman Catholic Diocese of Fall River, Massachusetts (diocese). After obtaining an extension for filing, the estate timely filed its Federal estate tax return on November 30, 2001. The estate claimed a charitable contribution deduction of $1,495,526 representing the claimed value of a charitable remainder interest given to the diocese. On Schedule O of the estate's Form 706, United States Estate (and Generation-Skipping Transfer) Tax Return, the following statement (return statement) was made: Charitable Remainder Roman Catholic Diocese of Fall River, Mass. Balance that is residue following 10 year term certain charitable remainder unitrust at 5% quarterly payments to two grand nieces Erica and Melissa Rodgerson, where during the term, the Trustee holds and operates pursuant to the terms and conditions of I.R.C. Sec. 664 and related provisions with balance at end of 10 year term to the Roman Catholic Diocese of Fall River, Mass. a 501(c)3 organization See attached calculations of Charitable Remainder Deductible. 4 The estate states on brief that John and Mary Tamulis were in their eighties when the trust was created, although there is no direct evidence of their age in the record.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011