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ESTATE OF CONE v. COMMISSIONER

Docket No. 37390-87.

60 T.C.M. 137 (1990)

T.C. Memo. 1990-359

Estate of Irma M. Ligon Cone, Deceased, Jimmy Cecil Cone, Executor v. Commissioner.

United States Tax Court.

Filed July 16, 1990.

Attorney(s) appearing for the Case

Rory Alan Boatright, P.O. Box 1, Round Mountain, Tex., for the petitioner. Phillip A. Pillar, for the respondent.

Memorandum Opinion

RAUM, Judge.

The Commissioner determined a deficiency in decedent's Federal estate tax in the amount of $125,817. After concessions the two issues left for decision are whether Jimmy Cecil Cone (Jimmy) is a "qualified heir" with respect to the decedent, as that term is defined in section 2032A of the Internal Revenue Code,1 and, if he is not a "qualified heir" with respect to the decedent, what portion of the...

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