Estate of Marie J. Jensen, Petitioner v. Commissioner of Internal Revenue Service, Respondent, T.C. Memo 2010-182, Dated August 10, 2010.

The Facts:                                           

Ms. Jensen was a resident of New York when she passed away on July 31, 2005.  Prior to her death, in February 2003, Ms. Jensen had created the Marie J. Jenson Revocable Trust and had appointed herself trustee.  Upon Ms. Jensen’s death, the trust held 164 shares of common stock in Wa-Klo, which equated to a controlling 82% equity interest in Wa-Klo.  Wa-Klo’s principal asset as of Ms. Jensen’s death was a 94-acre waterfront parcel of real estate which included athletic facilities, horse stables and a girl’s summer camp.  Wa-Klo was a C Corporation created in 1956 in the state of New Hampshire. [...]

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