Forbes v. Director

LASSER, J.T.C.

This case involves the New Jersey estate tax, a tax imposed in addition to the transfer inheritance tax, on the estates of resident decedents where the State inheritance taxes paid are not sufficient to fully absorb the federal state death tax credit (federal credit) allowed under § 2011 of the Internal Revenue Code (IRC). The federal credit reduces the federal estate tax by a percentage of the adjusted taxable estate upon proof of payment of state death taxes to any state or the District of Columbia in an amount equal to the allowed percentage.

At issue is the determination of…