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ESTATE OF COPLEY v. COMMISSIONER

Docket No. 18621.

15 T.C. 17 (1950)

ESTATE OF IRA C. COPLEY, DECEASED, THE FIRST NATIONAL BANK OF CHICAGO AND JAMES S. COPLEY, EXECUTORS OF THE WILL OF IRA C. COPLEY, DECEASED, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated July 18, 1950.

Attorney(s) appearing for the Case

Albert L. Hopkins, Esq., and Harry D. Orr, Jr., Esq., for the petitioner.

H. H. Hart, Esq., for the respondent.

OPINION.

MURDOCK, Judge:

The Commissioner determined a deficiency in gift taxes of the decedent for 1936 in the amount of $66,337.50 and a deficiency for 1944 in the amount of $51,955.58. The issues for decision are whether the transfers which the petitioner made in each of the taxable years were not subject to gift taxes for those years because they were made pursuant to a binding antenuptial agreement entered into in and made effective by the marriage...

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