Estate of Franklin A. Morse, Deceased, the First National Bank of Southwestern Michigan, Administrator v. Commissioner of Internal Revenue

Appellant, Estate of Franklin A. Morse, appeals a decision of the Tax Court (69 T.C. 408) denying a deduction to the estate for federal estate tax purposes. We conclude that the decision of the Tax Court was correct and therefore affirm.

The decedent, Franklin A. Morse, became a widower and Lueile H. Zimmer became a widow in their later years and, being old friends, Franklin began to court Lueile to the point that they contemplated marriage. Franklin’s home was in South Bend, Indiana and Lucile’s was in nearby Niles, Michigan. Lueile was a beneficiary of two trusts under her deceased husband’s…