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ESTATE OF FONTANA v. COMMISSIONER

Docket No. 6635-00.

118 T.C. 318 (2002)

118 T.C. No. 16

ESTATE OF ALDO H. FONTANA, DECEASED, RICHARD A. FONTANA AND JOAN F. REBOTARRO, CO-EXECUTORS, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 28, 2002.

Attorney(s) appearing for the Case

Owen G. Fiore, John F. Ramsbacher, and Erin M. Wilms, for petitioner.

G. Michelle Ferreira, for respondent.

OPINION

FOLEY, Judge:

By notice dated March 15, 2000, respondent determined an $830,720 Federal estate tax deficiency. The issue for determination is whether, for valuation purposes, stock owned outright by Aldo H. Fontana must be aggregated with stock over which he possessed a general power of appointment (GPA), exercisable only in his will (testamentary GPA).

Background

Aldo and Doris F. Fontana, husband and wife, had two...

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