ESTATE OF MILLIKIN v. COMMISSIONER

Docket No. 9928-93.

76 T.C.M. 1076 (1998)

T.C. Memo. 1998-456

Estate of Marguerite S. Millikin, Deceased, Quentin Alexander, Executor, and Severance A. Millikin Trust B, Society National Bank, f/k/a Ameritrust Company, Trustee v. Commissioner.

United States Tax Court.

Filed December 29, 1998.


Attorney(s) appearing for the Case

Robert E. Glaser, Cleveland, Ohio, for the petitioner. Dennis G. Driscoll, for the Respondent.


SUPPLEMENTAL MEMORANDUM FINDINGS OF FACT AND OPINION

COLVIN, Judge:

Respondent determined that the Estate of Marguerite S. Millikin (the estate) has an estate tax deficiency of $682,367 and that the Severance A. Millikin Trust B (Trust B) is liable for a generation-skipping transfer tax of $67,529. As then required by Estate of Park v. Commissioner, supra, we applied Ohio law to decide whether petitioners1 could...

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