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ESTATE OF SMITH v. COMMISSIONER

Docket No. 109946.

3 T.C.M. 495 (1944)

Estate of Abby R. Smith, Charles H. Welles, Jr., and G. D'Andelot Belin, Executors v. Commissioner.

United States Tax Court.

Entered May 23, 1944.

Attorney(s) appearing for the Case

C. H. Welles, 3rd., Esq., 1014 First Nat. Bank Bldg., Scranton, Pa., for the petitioners. Lewis S. Pendleton, Esq., for the respondent.

Memorandum Opinion

HILL, Judge:

This proceeding involves an estate tax deficiency of $10,365.72. The only contested issue is whether the value of certain property conveyed in trust by the decedent in 1919, less a life estate therein, is includible in the gross estate of the decedent. Respondent contends that such value is includible by reason of the provisions of either Section 302 (a) or Section 302 (c) of the...

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