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ESTATE OF PIDGEON v. COMMISSIONER

Docket No. 10961-93.

69 T.C.M. 2638 (1995)

T.C. Memo. 1995-218

Estate of Evelyn Walker Pidgeon, Deceased, First Tennessee Bank, National Association, Executor v. Commissioner.

United States Tax Court.

Filed May 18, 1995.

Attorney(s) appearing for the Case

Allan J. Wade, 2000 First Tennessee Bldg., Memphis, Tenn., for the petitioner. Edsel Ford Holman, Jr., for the respondent.

Memorandum Opinion

TANNENWALD, Judge:

Respondent determined a deficiency in petitioner's Federal estate tax in the amount of $118,392.49. The sole issue for decision concerns the correct amount to be included in petitioner's estate tax return pursuant to section 2044,1 which turns on the proper interpretation of the marital trust provision in the will of Evelyn Walker Pidgeon's spouse.

The facts have been fully stipulated...

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