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ESTATE OF GIRVIN v. COMMISSIONER

Docket No. 2396.

3 T.C.M. 1290 (1944)

Estate of Margaret Eyre Girvin, Deceased, The Bank of California, N. A., Executor v. Commissioner.

United States Tax Court.

Entered December 7, 1944.

Attorney(s) appearing for the Case

Edward Hale Julien, Esq., for the petitioner. Eugene Harpole, Esq., for the respondent.

Memorandum Opinion

OPPER, Judge:

Respondent determined a deficiency in estate tax in the amount of $14,344.29, all of which is in issue. The controversy arises because of respondent's inclusion in the gross estate, under section 811(c), Internal Revenue Code, of the subject matter of a transfer in trust made by decedent during her lifetime.

[The Facts]

The case was submitted upon a stipulation of facts, certain exhibits, and the...

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