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ESTATE OF CLOPTON v. COMMISSIONER

Docket No. 2047-82.

93 T.C. 275 (1989)

ESTATE OF SALLY H. CLOPTON, DECEASED, GEORGE M. MODLIN, EXECUTOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed August 29, 1989.

Attorney(s) appearing for the Case

Dennis I. Belcher and Kurt R. Magette, for the petitioner.

Scott D. Anderson, Robert J. Fitzpatrick, Calder L. Robertson, and Henry G. Salamy, for the respondent.

CLAPP, Judge:

Respondent determined a deficiency in petitioner's Federal estate tax of $85,708.96. The sole issue in this case is whether petitioner is entitled to an estate tax deduction under section 2055(a)1 for a bequest, pursuant to a trust agreement, of $190,395 to the Virginia Education Fund, Inc. (VEF).

FINDINGS OF FACT

Some of the facts have been stipulated and are so found. The stipulation of facts and...

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