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ESTATE OF TAMULIS v. COMMISSIONER OF INTERNAL REVENUE SERVICE

Docket No. 20721-03.

92 T.C.M. 189 (2006)

T.C. Memo. 2006-183

Estate of Anthony J. Tamulis, Deceased, Wanda Rodgerson, Executor and Trustee, Petitioner, v. Commissioner of Internal Revenue Service, Respondent.

United States Tax Court.

August 29, 2006.

Attorney(s) appearing for the Case

Hugh J. Graham III, for petitioner.

Thomas C. Pliske, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

GALE, Judge:

Respondent determined a deficiency in Federal estate tax of $745,177 for the Estate of Anthony J. Tamulis (the estate). The sole issue for decision is whether the estate is entitled to a deduction under section 20551 for the remainder interest of the Anthony J. Tamulis Trust (the trust). We hold that the estate is not.

FINDINGS OF FACT

Most of the facts have...

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