Arrington v. United States

ORDER

MILLER, Judge.

This case comes before the court after argument on cross-motions for summary judgment. The issues to be resolved are whether the Internal Revenue Code requires the inclusion of the following interests in the decedent’s gross estate: 1) the corpus of a trust held for the use and benefit of the decedent, 2) the date-of-death value of an annuity payable solely for the use and benefit of the decedent, and 3) $135,000.00 held by a court, and later paid to the decedent’s parents, for the use and benefit of the decedent.

FACTS

The following facts are undisputed. Deborah Arrington’s…