Estate of Leona Engelman, Peggy D. Mattson v. Commissioner

121 T.C. No. 4

UNITED STATES TAX COURT ESTATE OF LEONA ENGELMAN, DECEASED, PEGGY D. MATTSON, EXECUTOR, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 4668-02. Filed July 24, 2003. In 1990, H and D, husband and wife, established a living trust. The terms of the trust provided for an allocation of trust assets between two separate trusts, Trust A and Trust B, upon the death of the first spouse. Initially, all assets were to be placed in Trust A except to the extent disclaimed by the surviving spouse. Disclaimed assets were to be placed in Trust B. The surviving spouse was…