In Re Estate of Strock

This cause came on before the court upon an appeal by Joanne Limbach, Tax Commissioner of Ohio, from an order of the trial court determining that a payment made by the Estate of James Strock, deceased, was an allowable deduction under R.C.5731.16(A)(3). We reverse.

On the date of his death, decedent and his wife owned as joint tenants with right of survivorship certain real property located in Pima County, Arizona. Upon Mr. Strock's death, the legal title to his interest in the property passed to his wife by operation of law. The Arizona property was not included in the decedent's gross estate…