Estate of Winifred Hughes, Deceased, Dean McBride, Executor and Trustee, (2005)
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Estate of Winifred Hughes, Deceased, Dean McBride, Executor and Trustee, (2005)
T.C. Memo. 2005-296
UNITED STATES TAX COURT ESTATE OF WINIFRED HUGHES, DECEASED, DEAN McBRIDE, EXECUTOR AND TRUSTEE, Petitioner v.COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 21395-03. Filed December 27, 2005.David S. Grossman, for petitioner. Julie L. Payne, for respondent.MEMORANDUM FINDINGS OF FACT AND OPINION COLVIN, Judge: Respondent determined a deficiency of $175,801 in the estate's estate tax.Decedent's husband, George Robert Hughes (Bob Hughes), founded Bob Hughes Motors, Inc., d.b.a. Advance Leasing (Advance Leasing). Bob Hughes died in 1996. Winifred Hughes (decedent) was the sole owner of the stock of Advance Leasing from 1996 until she died in 1999. After Bob Hughes died, Dean McBride (McBride) became the sole officer and director of Advance Leasing. Decedent issued a durable power of attorney to McBride in 1996.In 1997, McBride executed an agreement and a promissory note on behalf of decedent and Advance Leasing which stated that decedent promised to pay $400,000 to Advance Leasing on demand in exchange for 4,000 shares of Advance Leasing's common stock. Advance Leasing issued a stock certificate to decedent for the 4,000 shares. McBride paid the $400,000 to Advance Leasing after decedent died in 1999.The issue...See the full content of this document
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