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ESTATE OF NICHOLSON v. COMMISSIONER

Docket No. 3635-88.

94 T.C. 666 (1990)

ESTATE OF T. BUFORD NICHOLSON, DECEASED, WILLIAM B. NICHOLSON, EXECUTOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 30, 1990.

Attorney(s) appearing for the Case

R. Clay Hoblit, for the petitioner.

William R. Leighton, for the respondent.

GERBER, Judge:

By notice of deficiency dated December 1, 1987, respondent determined a deficiency in estate taxes in the amount of $353,537.26. The issue for consideration is whether an interest in a trust created by the decedent qualifies for the estate tax marital deduction as qualified terminable interest property, within the meaning of section 2056(b)(7).1

FINDINGS OF FACT

The parties entered into a stipulation...

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