Prior to September 1985, a decedent executed a will directing that on her death, her property be distributed to her surviving spouse, children, grandchildren and charity. After she executed her will, the decedent was declared incompetent. She never regained competency up to and including the date of her death. The decedent’s estate timely filed an estate tax return and attached a copy of the decedent’s judgment of incompetency.
The decedent’s bene