Estate of Le Cear, et al. v. Comr., 135 T.C. 288 (2010)

(estate's credit for estate taxes paid limited by I.R.C. Sec. 2013(b) and (c); taxpayer, surviving spouse, had created intervivos trust with spouse that divided four ways on death of first spouse; first spouse made QTIP election on one of the shares and estate of survivor claimed credit for estate taxes paid in first spouse's estate but full credit not available because credit computed incorrectly and no credit available for state taxes paid by first spouse's estate - credit applies to federal estate tax paid only).

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