This proceeding involves a deficiency of $32,038.38 in estate tax and a delinquency penalty of $8,268.68. The issues are whether all or one-half of the agreed value of certain property placed in trust is includible in gross estate, and whether the penalty imposed for failure to file a timely return is proper.
FINDINGS OF FACT.
The petitioner is a national banking association acting as trustee of the trust estate of Frank N. Derby, who died at Salem, Oregon...
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