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ESTATE OF HIGGINS v. COMMISSIONER

Docket No. 11431-86.

91 T.C. 61 (1988)

ESTATE OF JOHN T. HIGGINS, DECEASED, MANUFACTURERS NATIONAL BANK OF DETROIT, PERSONAL REPRESENTATIVE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 19, 1988.

Attorney(s) appearing for the Case

Leonard J. Prekel, for the petitioner.

Roberta M. Hamm, for the respondent.

FEATHERSTON, Judge:

Respondent determined a deficiency in the Federal estate tax of the Estate of John T. Higgins in the amount of $185,813.46. The issue for determination is whether the personal representative of the estate made a valid qualified terminable interest property election under section 2056(b)(7).1

FINDINGS OF FACT

Manufacturers National Bank of Detroit (the bank), is the personal representative of...

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