ESTATE OF WALL v. COMMISSIONER

Docket No. 15311-91.

101 T.C. 300 (1993)

ESTATE OF HELEN S. WALL, DECEASED, KATHRYN H. BARTH, PERSONAL REPRESENTATIVE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 12, 1993.


Attorney(s) appearing for the Case

Gordon H. Smith, Jr., for petitioner.*

J. Paul Knap, for respondent.


OPINION

NIMS, Judge:

Respondent determined a $44,948 deficiency in the Federal estate tax due from the Estate of Helen S. Wall. The single issue for decision is whether property held by three irrevocable inter vivos trusts created by the decedent, Helen S. Wall (Mrs. Wall), is includable in her gross estate under section 2036(a)(2) or section 2038(a)(1) because in creating the trusts Mrs. Wall reserved the right to remove the sole trustee, a corporation...

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