ESTATE OF D. I. COOPER v. COMMISSIONER

Docket No. 2063.

7 T.C. 1236 (1946)

ESTATE OF D. I. COOPER, THE FIRST NATIONAL BANK OF PORTLAND (OREGON), EXECUTOR, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated November 29, 1946.


Attorney(s) appearing for the Case

Carl E. Davidson, Esq., and Charles P. Duffy, Esq., for the petitioner.

Wilford H. Payne, Esq., for the respondent.


Respondent has determined against the petitioner an estate tax deficiency of $17,500.80. Petitioner has acquiesced in all adjustments made by respondent except those whereby respondent included in the gross estate certain inter vivos transfers made by decedent to or for the benefit of his son, his wife, and his daughter. The issues for decision, therefore, are whether any of the transfers are includible under section 811 (c) of the Internal Revenue Code as having been...

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