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ESTATE OF ARMSTRONG v. COMMISSIONER

Docket No. 1118-98.

119 T.C. 220 (2002)

119 T.C. No. 13

ESTATE OF FRANK ARMSTRONG, JR., DECEASED, FRANK ARMSTRONG III, EXECUTOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed October 29, 2002.

Attorney(s) appearing for the Case

Aubrey J. Owen and Stephen L. Pettler, Jr., for petitioner.

Veena Luthra, Deborah C. Stanley, and Cheryl M.D. Rees, for respondent.

OPINION

THORNTON, Judge:

Respondent determined a $2,350,071 Federal estate tax deficiency with respect to the Estate of Frank Armstrong, Jr. (the estate). This case is before us on respondent's motion for partial summary judgment under Rule 121.1 Respondent seeks summary judgment upon the following issues: (1) Whether gift taxes of $4,680,284 paid by or on behalf of Frank Armstrong, Jr. (decedent), on gifts made within...

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