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ESTATE OF GILMAN v. COMMISSIONER

Docket No. 10748-02.

88 T.C.M. 627 (2004)

T.C. Memo. 2004-286

Estate of Howard of Gilman, Deceased, Bernard D. Bergreen and Natalie Moody, Executors, v. Commissioner.

United States Tax Court.

December 28, 2004.

Attorney(s) appearing for the Case

Thomas H. Moreland, Jeffrey S. Boxer, Jerome J. Caulfield and Richard B. Covey, for petitioner.

Milan K. Patel, Frank J. Jackson, and Gerard Mackey, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

COLVIN, Judge:

Respondent determined a $30,475,381.13 deficiency in the Federal estate tax of the Estate of Howard Gilman (the estate).

When Howard Gilman (decedent) died in 1998, his estate consisted primarily of stock of Gilman Investment Co., Inc. (GIC), a holding company for decedent's businesses and other assets (the Gilman assets). Before he died, decedent formed the Howard Gilman Foundation (the foundation...

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