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ESTATE OF LURIE v. COMMISSIONER

Docket No. 22639-94.

87 T.C.M. 830 (2004)

T.C. Memo. 2004-19

Estate of Robert H. Lurie, Deceased, Ann Lurie, Executor v. Commissioner.

United States Tax Court.

Filed January 28, 2004.

Attorney(s) appearing for the Case

Carleen L. Schreder, Robert M. Levin, Steven S. Brown, Royal B. Martin, Jr., Patricia E. Kaplan, William G. Sullivan, Daniel T. Hartnett, Samuel B. Sterrett, and Sheli Z. Rosenberg, for the petitioner.

John J. Comeau, James S. Stanis, James M. Cascino, and Patricia Pierce Davis, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

COLVIN, Judge.

Respondent determined a $47,459,641 deficiency in the Federal estate tax of the Estate of Robert H. Lurie (the estate). Respondent filed an amended answer asserting that the deficiency in Federal estate tax is $83,677,846.

Robert H. Lurie (decedent) created the Robert Lurie Revocable Trust (revocable trust), which, upon decedent's death, distributed property to a marital trust. The estate claimed...

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