Grimm v. Commissioner

Prior to D's death, D and P, American citizens, were husband and wife and resided in the Philippines. Following D's death, P moved back to the State of Utah where D's estate was probated. Under Philippine law, the relationship between a husband and wife is classified as a "conjugal partnership," a concept substantially similar to the relationship under the community property laws of the State of Washington. At the time of D's death, the "conjugal partnership" between D and P was owed approximately $ 3 million, due and payable, in accord with a prior agreement, in the remaining three of five…