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ESTATE OF HIRSCH v. COMMISSIONER

Docket No. 19585.

14 T.C. 509 (1950)

THE ESTATE OF SAMUEL HIRSCH, DECEASED, LENA HIRSCH, BEATRICE ABRAMS, EVELYN LIROFF AND ALICE HARKAVY, EXECUTRICES, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated March 30, 1950.

Attorney(s) appearing for the Case

Israel Harkavy, Esq., for the petitioners.

J. Richard Riggles, Jr., Esq., for the respondent.

This proceeding involves a deficiency of $11,649.55 in estate tax. The sole issue is whether property owned jointly by the decedent and his wife and insurance on the decedent's life, payable to his wife as sole beneficiary, are "property subject to claims" within the meaning of section 812 (b) of the Internal Revenue Code.

The facts have been stipulated by the parties and are hereby adopted.

FINDINGS OF FACT.

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