Iandoli v. Iandoli

HERSEY, Chief Judge.

Lewis E. Iandoli died testate in 1982, leaving one-half of his residuary estate to his wife, Angelina Iandoli (appellee), who was also named personal representative of the estate. The other one-half of the residuary was left to appellant, Marie Iandoli, decedent’s daughter by a previous marriage. The will contained no provision for payment or apportionment of estate taxes.

Federal estate taxes of $1,111,151.00 came due in November 1982, and there was a tax liability to the State of Florida in the amount of $194,233.00. Appellee, as personal representative, deferred payment…