EFTA01103666Set 9
20p12,308w
value of certain shares of stock transferred
HOWARD GILMAN, CHARLES GILMAN, JR., by decedent to an irrevocable trust in 1948 is required to
AND SYLVIA P. GILMAN, EXECUTORS, be included ... decedent's *297 gross estate under section
PETITIONERS 2036(a).' The answer depends upon whether decedent
v. retained the enjoyment of the stock within the meaning of
COMMISSIONER OF INTERNAL ... FACT
*296 James B. Lewis and Maurice Austin, for the
petitioners. Charles Gilman (hereinafter decedent or Charles) died
testate on June 19, 1967. His wife, Sylvia P. Gilman, and
Agatha
https://www.justice.gov/epstein/files/DataSet%209/EFTA01103666.pdf
EFTA00130065Set 9
2019-08-1784p15,798w
Rules.
OCME has been ordered to produce certified copies of documents concerning decedent,
Jeffrey Edward Epstein ME # M19-19432
OCME is a governmental office organized under the New York City ... OFFICE OF CHIEF MEDICAL EXAMINER
CITY OF NEW YORK
REPORT OF AUTOPSY
Name of Decedent: Jeffrey Edward Epstein M.E. #: M-19-019432
Autopsy Performed by: M, M.D. Date of Autopsy ... YORK
OFFICE OF CHIEF MEDICAL EXAMINER
520 FIRST AVE NEW YORK, NY 10016
Decedent Name : Jeffrey Edward Epstein Laborakiry No : FT19-03508
Medical Examiner: ME Case
https://www.justice.gov/epstein/files/DataSet%209/EFTA00130065.pdf
EFTA01130961Set 9
2011-10-2253p26,485w
from a decedent or passed from a decedent if the property is "acquired by
bequest, devise, or inheritance, or by the decedent's estate from the decedent, whether the
property ... acquired under the decedent's ill or under the law governing the descent and
distribution of the property of decedents."151 The commentators view this additional language as
meaning that ... acquired by reason
of the death of the prior decedent or by bequest, devise, or inheritance from the prior decedent)
shall be included in the gross income, for the taxable
https://www.justice.gov/epstein/files/DataSet%209/EFTA01130961.pdf
EFTA01063319Set 9
2017-02-2211p8,936w
respondent's determination that the estate underreported
the values of two paintings held by decedent at her death on August 31, 2005 (valuation date). After concessions,
2 the sole issue ... Internal Revenue Code of 1986, as amended
and in effect for the date of decedent's death, and all Rule references are to the Tax Court Rules of
Practice ... respondent's determination that the
estate failed to report
taxable gifts made by decedent Eva Franzen Kollsman for taxable years 2002, 2003, and 2004. The
estate has conceded this adjustment
https://www.justice.gov/epstein/files/DataSet%209/EFTA01063319.pdf
EFTA01221462Set 9
2010-12-1721p7,870w
amount of
the Making Work Pay credit, the two percent OASDI
$5 million, for decedents dying after 2009 and
reduction is available to all wage earners, with no before ... decedents dying after 2009, but at a signifi-
40,000 60,000 8,200 24
cantly higher exclusion amount and lower tax rate ... revived retroactively for 150,000 250,000 38,800 32
2010. However, estates of decedents dying in 2010 can 250,000 500,000 70,800 34
elect
https://www.justice.gov/epstein/files/DataSet%209/EFTA01221462.pdf
EFTA00812635Set 9
23p9,019w
ends
when an income interest ends.
(2) "Beneficiary" includes, in the case of a decedent's estate, an heir, legatee, and
devisee and, in the case of a trust ... Terms of a trust" means the manifestation of the intent of a senior or decedent
with respect to the trust, expressed in a manner that admits of its proof ... receipt or charge an expenditure to income or principal with respect to a
decedent's estate, a trust, or property passing to a trust, that is eligible for a federal
https://www.justice.gov/epstein/files/DataSet%209/EFTA00812635.pdf
EFTA01469000Set 10
17p4,605w
certain exceptions to this rule, including
an annuity acquired by
the estate of a decedent because of the death of the decedent.
1. Treatment of Scheduled Payments on the Annuity ... period is included in gross income
when received of (A)
the estate of the decedent, if the right to receive the amount is acquired
by the decedent's estate
from ... decedent; (B) the person who, by reason of the death of the
decedent, acquires the right
to receive the amount if the right to receive the amount is not acquired
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01469000.pdf
EFTA01097356Set 9
68p35,148w
Philadelphia Trust Co. v. Smith, 356 U.S. 274 (1958),
which holds that where a decedent has transferred property to another in return for a promise to make periodic payments ... decedent's lifetime, the payments are not income from the uansferred property so as to cause inclusion of that property
in the decedent's estate, if the payments ... fully applicable to the
case at bar."
In Moss v. Comm'r,I8 the decedent sold his stock in his closely held company to
the company in return
https://www.justice.gov/epstein/files/DataSet%209/EFTA01097356.pdf
EFTA01104587Set 9
42p20,799w
gross estate.
(4) Basis adjustment
The basis of a partnership interest acquired from a decedent is the fair
market value of the interest at death, less §691 items, increased ... property becomes $2.1 million.
However, §1014(e) bars a basis adjustment if the decedent acquired the
asset within a year of death and bequeaths the asset to the person from ... whom the
decedent acquired the asset. By its terms, §I014(e) is not applicable if Alice does
not die within a year of Adam giving the partnership interest
https://www.justice.gov/epstein/files/DataSet%209/EFTA01104587.pdf
satisfied: (1) the decedent made an inter vivos transfer of property, (2) the decedent retained an
interest or right in the transferred property, and (3) the decedent's transfer ... Courts' analysis focused
on the second and third condition of 2036(a).
Did the decedent retain an interest or right in the transferred property?
Property is included in a decedent ... gross estate if the decedent retained, by express or implied
agreement, possession, enjoyment, of the right to income from the transferred property.
The Estate's primary argument was that
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01459940.pdf
EFTA00076892Set 9
2019-12-31100p14,301w
Account (Paris) 4 133,200.00 4
SUBTOTAL $ 7,598,839.00
yALUE,
Vehicles Titled in Decedent's Names
• 2018 Chevrolet Suburban6 S 38,000.00 5
• 2017 Maverick ... inventory.
2 Values provided are as of 12/31/2019, unless otherwise noted.
The entirety of Decedent's personal account, $8,554,622.64, was transferred into the Estate's checking account held ... value in USD is $133,200.00.
5 The vehicles titled in the Decedent's name are located outside of the U.S. Virgin Islands but have been
included to ensure
consistency
https://www.justice.gov/epstein/files/DataSet%209/EFTA00076892.pdf
EFTA00076491Set 9
2019-12-31100p14,323w
Account (Paris) 4 133,200.00 4
SUBTOTAL $ 7,598,839.00
yALUE,
Vehicles Titled in Decedent's Names
• 2018 Chevrolet Suburban6 S 38,000.00 5
• 2017 Maverick ... inventory.
2 Values provided are as of 12/31/2019, unless otherwise noted.
The entirety of Decedent's personal account, $8,554,622.64, was transferred into the Estate's checking account held ... value in USD is $133,200.00.
5 The vehicles titled in the Decedent's name are located outside of the U.S. Virgin Islands but have been
included to ensure
consistency
https://www.justice.gov/epstein/files/DataSet%209/EFTA00076491.pdf
EFTA00805272Set 9
2017-07-3156p12,681w
matter, the Court finds that:
1. Karen Elizabeth Kiaer a.k.a. Karen Lis Kjae: (the
"decedent") died a resident of 011on. Chesieres, Switzerland.
2. The decedent died ... Chalet
"Aloe", 011on, Chesieres, Switzerland.
3. The decedent left a Lant Will and Testament dated
September 7, 1979 (the "Will"), which Will was admitted to
probate by the Justice ... Circuit of 011on, Lausanne,
Switzerland.
4. The domiciliary Executor of the estate of the
decedent (the "estate") is Christian !War of Frederiksberggade,
24, 5, 1459 Copenhagen, Denmark.
5. The death
https://www.justice.gov/epstein/files/DataSet%209/EFTA00805272.pdf