Estate of Eleanor R. Gerson, Allan D. Kleinman v. Commissioner

127 T.C. No. 11

UNITED STATES TAX COURT ESTATE OF ELEANOR R. GERSON, DECEASED, ALLAN D. KLEINMAN, EXECUTOR, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 13534-04. Filed October 24, 2006. G created the Benjamin Gerson Trust which became irrevocable when G died in 1973. The trust provided for the creation of a marital trust (the trust) for the benefit of G’s wife, D. The trust conferred upon D a general power of appointment over the trust property. D died in October 2000 and left a will under which she exercised the power of appointment in favor of her grandchildren. R…