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ESTATE OF CHANCELLOR v. COMMISSIONER OF INTERNAL REVENUE

No. 7973-09.

T.C. Memo. 2011-172

ESTATE OF ANN R. CHANCELLOR, DECEASED, MARY ANN C. WALKER, EXECUTRIX, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed July 14, 2011.

Attorney(s) appearing for the Case

Harris H. Barnes, III , for petitioner.

John F. Driscoll , for respondent.

MEMORANDUM OPINION

THORNTON, Judge.

Respondent determined a $716,013 Federal estate tax deficiency. After various concessions by respondent, the sole issue for decision is whether pursuant to section 2041 the gross estate of Ann R. Chancellor (decedent) must include the value of the assets of a trust of which she was a beneficiary and trustee.1 She died November 16, 2004, and at the time of her death was domiciled in Mississippi...

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