Estate of Lucien J. Le Caer, Lorraine Le Caer-Domini, Co-Trustee and Denise Le Caer Stagner, Co-Trustee v. Commissioner

OPINION

Marvel, Judge:

Respondent determined a $2,400 deficiency in the Federal estate tax of the Estate of Lucien Le Caer (Mr. Le Caer) and a $227,399 deficiency in the Federal estate tax of the Estate of Marie L. Le Caer (Mrs. Le Caer). After concessions, 2 the issues for decision are: (1) Whether and to what extent Mrs. Le Caer’s estate may claim a credit under section 2013 for Federal estate tax paid on the transfer of property to Mrs. Le Caer from Mr. Le Caer’s estate; (2) whether Mrs. Le Caer’s estate may decrease the gross estate by or claim as an allowable deduction the amount of the…