Estate of Le Caer v. Commissioner
United States Tax Court
135 T.C. 288 (2010)
- Written by Daniel Clark, JD
Facts
Lucien Le Caer died, and most of his multimillion-dollar estate went to his wife, Marie Le Caer. However, because of some of Lucien’s estate-planning choices, $495,000 of property that passed to Marie did not qualify for the marital deduction and was accordingly subject to the federal estate tax. Lucien’s estate paid $225,000 total in federal and state estate taxes on that transferred property. Marie died less than three months later. Marie’s estate (plaintiff) sought to claim a $225,000 credit on Marie’s own estate tax liability pursuant to § 2013 of the Internal Revenue Code. The Internal Revenue Service (IRS) (defendant) agreed that Marie’s estate qualified for a credit pursuant to § 2013, but for an amount substantially lower than $225,000. The two decedents’ respective estates petitioned the tax court to resolve the dispute.
Rule of Law
Issue
Holding and Reasoning (Marvel, J.)
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