ESTATE OF SCHMIDT v. COMMISSIONER

Docket No. 26186.

19 T.C. 54 (1952)

ESTATE OF ARTHUR A. SCHMIDT, DECEASED, MARJORIE MOSHER SCHMIDT, EXECUTRIX, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated October 20, 1952.


Attorney(s) appearing for the Case

A. R. Kimbrough, Esq., for the petitioner.

Raymond B. Sullivan, Esq., for the respondent.


OPINION.

HARRON, Judge:

The respondent determined a deficiency in estate tax in the amount of $5,720.18. The petitioner agrees with some adjustments made by the respondent. The respondent agrees that the petitioner is entitled to a further deduction for attorneys' fees and costs. Effect will be given to these agreements of the parties under Rule 50.

The only question to be decided is whether property given to the decedent in 1946, consisting...

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