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ESTATE OF SMITH v. COMMISSIONER

Docket No. 30821-88.

94 T.C. 872 (1990)

ESTATE OF FREDERICK R. SMITH, DECEASED, FREDERICK D. SMITH AND KAY A. HEMINGWAY, PERSONAL REPRESENTATIVES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 13, 1990.

Attorney(s) appearing for the Case

Thomas C. Gores, Don Paul Badgley, Joseph A. McIntosh, and Douglas L. Phillips, for the petitioner.

Blake W. Ferguson and Terry W. Vincent, for the respondent.

OPINION

TANNENWALD, Judge:

This case is before the Court on respondent's motion for partial summary judgment in respect of the basis for determining the value of certain gifts for purposes of the estate tax.

At the time the petition was filed, petitioner's personal representatives, Frederick D. Smith and Kay A. Hemingway, resided in Seattle and Mercer Island, Washington, respectively.

On December 22, 1982, the decedent, Frederick R...

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