United States Tax Court December 21, 2009, No. 26212-06 (Estate of Morgens v. Comm'r)

lead-opinion

OPINION

Marvel, Judge:

Respondent determined a $4,684,430 deficiency in the Federal estate tax of the Estate of Anne W. Morgens (Mrs. Morgens). The sole issue1 for decision is whether the amounts of gift tax paid with respect to Mrs. Morgens’ deemed gifts of remainder interests in qualified terminable interest property (QTIP) are includable in her gross estate under section 2035(b).