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estate tax of the Estate of Hilde E. Erickson (the estate).1
After concessions, we are asked to decide whether property Hilde
E. Erickson (decedent or Mrs. Erickson) transferred to a family
limited partnership shortly before her death is included in her
gross estate under section 2036(a)(1).2 We hold that it is.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the accompanying exhibits are
incorporated by this reference. Karen E. Lange (Karen),
decedent’s eldest daughter and the personal representative of the
estate, resided in Longboat Key, Florida, when the estate filed
the petition. Mrs. Erickson resided in Minnesota when she died,
and her estate was admitted to probate in the Steele County
District Court in Minnesota.
The Erickson Family
Mrs. Erickson and her husband, Arthur E. Erickson (Mr.
Erickson), met at Marquette University, where Mr. Erickson was
studying dentistry and Mrs. Erickson was studying dental hygiene.
Mr. and Mrs. Erickson worked together before they married and,
after they married, moved to Reedsburg, Wisconsin, where Mr.
1These cases have been consolidated for purposes of
briefing, trial, and opinion.
2All section and Code references are to the Internal Revenue
Code, and all Rule references are to the Tax Court Rules of
Practice and Procedure, unless otherwise indicated.
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