Supreme Court of South Carolina February 27, 1995, 24199 (Estate of Gerhard v. Cram)

Moore, Justice:

This is a will construction case involving allocation of the liability for estate taxes. We affirm in part and reverse in part.

FACTS

Decedent Gerhard died September 16, 1990. At the time of his death, Decedent’s gross estate for purposes of federal and state estate tax liability1 included the following assets:

1) Real estate $1,200,000.00

2) Mortgages, notes and cash 134,134.