Audrey J. Walton v. Commissioner

115 T.C. No. 41

UNITED STATES TAX COURT AUDREY J. WALTON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 3824-99. Filed December 22, 2000. P established and funded with corporate stock two substantially identical grantor retained annuity trusts (GRAT’s). Each GRAT had a 2-year term during which P retained the right to receive an annuity. In the event that P died prior to expiration of the 2-year term, the remaining scheduled annuity payments were to be made to her estate. The balance of the trust property would then be paid to the remainder beneficiaries. Held: For…