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ESTATE OF LA MERES v. COMMISSIONER

Docket No. 6909-88.

98 T.C. 294 (1992)

ESTATE OF EUGENE E. LA MERES, DECEASED, KATHY KOITHAN, PERSONAL REPRESENTATIVE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 23, 1992.

Attorney(s) appearing for the Case

William S. Huff, Charles A. Ramunno, Todd A. Fisher, and David R. Child, for petitioner.

Frederick J. Lockhart, Jr., for respondent.

RUWE, Judge:

Respondent determined a deficiency in petitioner's Federal estate tax in the amount of $11,786,621, and additions to tax under section 6651(a)(1)1 in the amount of $3,718,725, and under section 6651(a)(2) in the amount of $618,326.

The issues for decision are: (1) Whether the split interest charitable provisions of the Eugene E. La Meres Revocable Trust, which were modified...

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