ESTATE OF SHANNON v. COMMISSIONER

Docket No. 34918-87.

60 T.C.M. 1361 (1990)

T.C. Memo. 1990-614

Estate of Warren J. Shannon, Deceased, Oveida E. Shannon, Personal Representative v. Commissioner.

United States Tax Court.

Filed December 5, 1990.


Attorney(s) appearing for the Case

Richard C. Schmoker and Charles T. Parks, Jr., 90 S. Seventh St., Minneapolis, Minn., for the petitioner. Ellen T. Friberg, for the respondent.


Memorandum Findings of Fact and Opinion

CLAPP, Judge:

Respondent determined a deficiency in petitioner's estate tax of $43,677.21. After concessions by respondent, the issues are (1) whether, under the Minnesota apportionment statute, the Federal and State estate taxes are to be apportioned among bequests and devises, which gave rise to the tax, or paid entirely out of the residue which qualifies for the...

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