ESTATE OF RAPP v. C.I.R.

No. 96-70742.

140 F.3d 1211 (1998)

ESTATE OF Bert B. RAPP, Deceased; Richard L. Rapp, Executor, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided March 18, 1998.

Amended on Partial Grant of Rehearing May 15, 1998.


Attorney(s) appearing for the Case

Gerald E. Lunn, Jr., Los Angeles, California, for petitioner-appellant.

Richard Farber, Washington, DC, for respondent-appellee.

Before: FLETCHER, MAGILL, and T.G. NELSON, Circuit Judges.


FLETCHER, Circuit Judge:

The executor of Mr. Bert Rapp's estate appeals the tax court's determination that a trust established by Mr. Rapp does not qualify as "qualified terminable interest property" (QTIP), as defined by 26 U.S.C. § 2056(b)(7). As such, the value of the trust may not be deducted when determining federal estate taxes owed.

We have jurisdiction, 26 U.S.C. § 7482, and we affirm.

I.

The testator, Mr. Bert Rapp, died...

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