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ESTATE OF CARLE v. COMMISSIONER

Docket No. 1660.

3 T.C.M. 540 (1944)

Estate of John J. Carle, deceased, by Robert W. Carle, Susan C. Edwards and Edward H. Carle, as executors of the will of John J. Carle, deceased v. Commissioner.

United States Tax Court.

Entered June 7, 1944.

Attorney(s) appearing for the Case

William Harrison, Esq., and William Imhof, Esq., 43 Cedar St., New York, N. Y., for the petitioners. Clay C. Holmes, Esq., for the respondent.

Memorandum Opinion

DISNEY, Judge:

This case involves estate tax, a deficiency having been determined in the amount of $82,586.29, and the petitioners contending for an overpayment of $33,147.66. The only question here presented is whether the Commissioner erred in including in decedent's gross estate $240,076.46 as the value of a gift by inter vivos trust by the decedent as a transfer intended to take effect in possession or enjoyment at or after...

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