Estate of Mary King Patterson, James J. Patterson v. Commissioner of Internal Revenue

The Estate of Mary King Patterson, James J. Patterson, Executor (the Estate), appeals from a decision of the United States Tax Court, Irene Scott, Judge, which sustained the Tax Commissioner’s determination of a deficiency of $729,624.76 in federal estate taxes. We affirm substantially for the reasons stated in the opinion of the Tax Court, T.C.Memo. 1983-381 (June 27, 1983).

The facts of this case were stipulated to by the parties and are well summarized in the Tax Court opinion. The only question before the Tax Court and before us on appeal is whether the remainder interest in a testamentary…