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ESTATE OF HICKS v. COMMISSIONER

Docket No. 13779-02.

94 T.C.M. 43 (2007)

T.C. Memo. 2007-182

Estate of Kimberly A. Hicks, Deceased, Key Trust Company of Ohio, N.A., Administrator, Petitioner v. Commissioner.

United States Tax Court.

Filed July 10, 2007.

Attorney(s) appearing for the Case

Timothy G. Crowley, for petitioner.

Robert D. Kaiser, for respondent.

Opinion by Judge Holmes.

MEMORANDUM OPINION

HOLMES, Judge:

Kimberly Hicks, while still a toddler, was severely disabled in a collision at a railroad crossing. Litigation followed, and the largest part of the ultimate settlement was a lump sum to be allocated between Kimberly and her father. The Ohio court that allocated that lump sum gave over $1.4 million to her father, but with the full expectation that he would immediately lend $1 million to a special trust for Kimberly's benefit...

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