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ESTATE OF SINGER v. COMMISSIONER

Docket No. 3867.

4 T.C.M. 960 (1945)

Estate of Franklin Morse Singer, Deceased, Hall Park McCullough, Frederick G. I. Singer and Emilie L. H. Singer, Executors v. Commissioner.

United States Tax Court.

Entered October 3, 1945.

Attorney(s) appearing for the Case

Montgomery B. Angell, Esq., Otis T. Bradley, Esq., George Craven, Esq., 15 Broad St., New York, N. Y., and John G. Saxe, Esq., 102 Maiden Lane, New York, N. Y., for the petitioners. Thomas H. Lewis, Jr., Esq., for the respondent.

Memorandum Findings of Fact and Opinion

The Commissioner determined a deficiency of $508,985.71 in estate tax. The petitioners claim an overpayment. The issues submitted for decision are: (1) Whether the corpus of three irrevocable trusts created by the decedent in 1891 and 1902 are includable in his gross estate as transfers to take effect in possession or enjoyment at or after death within the meaning of section 811 (c), I. R. C.; (2) what was the value on August...

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