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ESTATE OF BIGELOW v. COMMISSIONER

Dkt. No. 4066-02.

89 T.C.M. 954 (2005)

T.C. Memo. 2005-65

Estate of Virginia A. Bigelow, Deceased, Franklin T. Bigelow, Jr., Executor v. Commissioner.

United States Tax Court.

March 30, 2005.

Attorney(s) appearing for the Case

Joseph F. Moore, for petitioner;

Donna F. Herbert, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

COLVIN, Judge:

Respondent determined a $217,480.05 deficiency in the Federal estate tax of the Estate of Virginia A. Bigelow.

Virginia A. Bigelow (decedent) established a trust (decedent's trust) and transferred her residence to it in 1991. The trust exchanged the residence for other real property in 1993. Decedent's trust and decedent's children formed a family limited partnership in 1994 when decedent was...

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