The issue remaining for decision is whether the estate of Elwood H. Olsen is required under section 20441 to include in the value of Elwood H. Olsen’s gross estate $1,001,905.51, the value on the applicable alternate valuation date of all of the assets that a certain trust held on the date of his death. We hold that that estate is required under section 2044 to include in the value of that gross estate $607,927.51, the value on the applicable valuation date of only certain of the assets that that trust held on the date of Mr. Olsen’s death.
FINDINGS OF FACT
All of the facts in this case, which the parties submitted under Rule 122, have been stipulated by the parties and are so found except as noted below.
On February 25, 2008, Elwood H. Olsen (Mr. Olsen or decedent), who was 92 years old, died testate in the State of Florida. Elwood Ty Olsen (Ty Olsen or personal representative), one of decedent’s three children, is the personal representative of the estate of Mr. Olsen (Mr. Olsen’s estate). Ty Olsen resided in Illinois at the time he filed the petition.
Mr. Olsen received a college degree in 1938 from Morningside College (sometimes, Morningside) in Sioux City, Iowa, and a law degree in 1941 from the University of Iowa College of Law. After having served in the U.S. Navy during World War II, Mr. Olsen received a master of laws degree from George Washington University in Washington, D.C. In 1990, Morningside awarded him the honorary degree of doctor of laws.
Judge(s): Carolyn P. Chiechi
Jurisdiction: U.S. Tax Court
Related Categories: Taxation
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|Joel McMahan||Internal Revenue Service|