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ESTATE OF DISBROW v. COMMISSIONER

Dkt. No. 6739-04.

91 T.C.M. 794 (2006)

T.C. Memo. 2006-34

Estate of Lorraine C. Disbrow, Deceased, Martha D. Johnson, Executrix v. Commissioner

United States Tax Court.

February 28, 2006.

Attorney(s) appearing for the Case

Terrence E. Smolev, for petitioner.

Marie E. Small, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

LARO, Judge:

Petitioner petitioned the Court to redetermine a $426,377.57 deficiency that respondent determined in the Federal estate tax pertaining to the Estate of Lorraine C. Disbrow, Deceased (decedent's estate). Following concessions, we decide whether the fair market value of the residence (residence) of Lorraine C. Disbrow, Deceased (decedent), is includable in her gross estate under section 2036(a)(1).

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