ESTATE OF WORTHINGTON v. COMMISSIONER

Docket No. 25975.

18 T.C. 796 (1952)

ESTATE OF LESLEY DIANA WORTHINGTON, HARRY FRASER KER, IN HIS CAPACITY AS SUPERINTENDENT OF THE TRUSTEE DEPARTMENT OF BARCLAYS BANK (DC&O), AND AS SUCH THE NOMINEE OF SAID BANK, AND AS SUCH THE EXECUTOR TESTAMENTARY OF THE ESTATE OF LESLEY DIANA WORTHINGTON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated July 25, 1952.


Attorney(s) appearing for the Case

Robert G. Starr, Esq., and Walter J. Neylon, Esq., for the petitioner.

Ellyne E. Strickland, Esq., for the respondent.


The respondent determined a deficiency in Federal estate tax in the amount of $13,097.96, based upon the inclusion in evaluating the decedent's gross estate, of certain items owned by the decedent, a nonresident alien not engaged in business in the United States.

The questions presented are as follows:

1. In determining the value of the decedent's interest in the estate of her grandfather for estate tax purposes, is the petitioner entitled to exclude from...

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