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ESTATE OF HIBBS v. COMMISSIONER

Docket Nos. 111541, 111542.

16 T.C. 535 (1951)

ESTATE OF WILLIAM BEALE HIBBS, DECEASED, AMERICAN SECURITY AND TRUST COMPANY, TRUSTEE AND TRANSFEREE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. ESTATE OF WILLIAM BEALE HIBBS, DECEASED, TRANSFEROR, JOHN S. FLANNERY, TRUSTEE AND TRANSFEREE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated February 28, 1951.

Attorney(s) appearing for the Case

C. L. Aiello, Esq., and G. Bowdoin Craighill, Jr., Esq., for the petitioners.

Sanford M. Stoddard, Esq., for the respondent.

The respondent originally determined a deficiency of $56,283.51 in the estate tax liability of William Beale Hibbs, deceased. Most of that deficiency arose out of respondent's determination that the reversionary interest in property transferred to four trusts and the entire corpus of a fifth trust were includible in decedent's gross estate. At the hearing it was conceded that no interest in the five trusts above was includible. The...

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