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ESTATE OF SPIEGEL v. COMMISSIONER

Docket No. 1662.

4 T.C.M. 256 (1945)

Estate of Sidney M. Spiegel, Deceased, Sidney M. Spiegel, Jr., Katherine J. Spiegel and Robert Michels, Executors v. Commissioner.

United States Tax Court.

Entered February 24, 1945.

Attorney(s) appearing for the Case

Harry Thom, Esq., 231 S. La Salle St., Chicago, Ill., for the petitioners. Harold H. Hart, Esq., for the respondent.

The Commissioner determined a deficiency of $454,788.58 in estate tax. The only question is whether the value of the corpus of a trust created by the decedent during his lifetime is includable in gross estate under Section 811 (c), Internal Revenue Code.

Findings of Fact

The petitioners are the executors of the estate of Sidney M. Spiegel, who was born August 16, 1872, and died testate on December 19, 1940. The executors filed the estate tax return in Chicago...

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