ESTATE OF HARDESTY v. COMMISSIONER

Docket No. 29670.

11 T.C.M. 359 (1952)

Estate of Rudd Hardesty, Deceased, The Denver National Bank, Executor v. Commissioner.

United States Tax Court.

Entered April 15, 1952.


Attorney(s) appearing for the Case

Guy K. Brewster, Esq., 1011 University Bldg., Denver, Colo., for the petitioner. Wm. B. Springer, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

JOHNSON, Judge:

This proceeding involves a deficiency in estate tax of $50,863.46, as determined by the Commissioner. Petitioner claims a refund for overpayment in the Gladys V. January Trust.

The question for our determination is what part of the corpus of each of the five trusts created by the decedent on July 1, 1935, is includible in his gross estate under section 811 (c) and section 811 (d) (2) of the...

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