Estate of Wayne-Chi Young, Tsai-Hsiu Hsu Yang v. Commissioner

110 T.C. No. 24

UNITED STATES TAX COURT ESTATE OF WAYNE-CHI YOUNG, DECEASED, TSAI-HSIU HSU YANG, EXECUTRIX, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 20139-94. Filed May 11, 1998. Decedent and his wife Yang owned real property in California, a community property State. Decedent's Federal Estate Tax Return reported 50 percent of the date of death value of the property as decedent's interest therein under sec. 2033, I.R.C., and then claimed a 15-percent fractional interest discount under Propstra v. United States,

680 F.2d 1248

(9th Cir. 1982). After filing the estate…