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ESTATE OF RECTOR v. COMMISSIONER

Dkt. No. 20860-05.

94 T.C.M. 567 (2007)

T.C. Memo. 2007-367

Estate of Concetta H. Rector, Deceased, John M. Rector II, Co-Executor and Co-Trustee v. Commissioner.

United States Tax Court.

December 13, 2007.

Attorney(s) appearing for the Case

Edwin C. Anderson, Jr., Daniel E. Post, and Michael D. Maciel, for petitioner.

Alan E. Staines, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

LARO, Judge.

Petitioner petitioned the Court to redetermine a $1,633,049 Federal estate tax deficiency and a $92,790 accuracy-related penalty under section 6662(a).1 Following concessions, we decide whether Concetta H. Rector (decedent) retained the possession or enjoyment of, or the right to the income from, property transferred to Rector Limited Partnership (RLP) for purposes of section...

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