ESTATE OF HUGHES v. COMMISSIONER

Docket No. 8139.

7 T.C. 1348 (1946)

ESTATE OF EDWARD P. HUGHES, HELEN H. ROONEY, ADMINISTRATRIX, C. T. A., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated December 16, 1946.


Attorney(s) appearing for the Case

Osborne A. McKegney, Esq., for the petitioner.

Martin M. Lore, Esq., for the respondent.


Respondent has determined a deficiency of $4,512.91 in estate tax. The issue is whether the value, at decedent's death, of certain property theretofore transferred by him in trust is to be included in his gross estate for estate tax purposes under section 811 (c) of the Internal Revenue Code.

FINDINGS OF FACT.

The petitioner, Helen H. Rooney, is the legally qualified administratrix of the estate of Edward P. Hughes, who died testate on December 19, 1939...

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