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ESTATE OF CURIE v. COMMISSIONER

Docket No. 2142.

4 T.C. 1175 (1945)

ESTATE OF CHARLES CURIE, DECEASED, THE SECOND NATIONAL BANK OF PATERSON, AS EXECUTOR, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated April 25, 1945.

Attorney(s) appearing for the Case

Frederick M. Schlater, Esq., and William H. Welsh, Esq., for the petitioner.

Walt Mandry, Esq., for the respondent.

This proceeding involves a deficiency in estate tax in the amount of $95,299.69 and a penalty for delinquency in filing the estate tax return in the amount of $35,257.23. The deficiency resulted from several adjustments, two of which, involving the inclusion in decedent's gross estate of the corpus of two trusts created by decedent, are alleged as error. The correctness of the penalty is also contested. It is agreed that petitioner shall be entitled to credit for state inheritance...

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