ESTATE OF RESCH v. COMMISSIONER

Docket No. 26512.

20 T.C. 171 (1953)

ESTATE OF ARNOLD RESCH, DECEASED, THE CHASE NATIONAL BANK OF THE CITY OF NEW YORK, ANCILLARY EXECUTOR, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated April 27, 1953.


Attorney(s) appearing for the Case

Thomas A. Ryan, Esq., for the petitioner.

Rigmor O. Carlsen, Esq., for the respondent.


The Commissioner has determined a deficiency in estate tax in the amount of $95,061.06. The deficiency is due principally to the inclusion in the gross estate by the respondent of the value, as of the date of decedent's death, of the corpora of two trusts. Other adjustments made by the Commissioner have been settled by stipulation of the parties and will be given effect under Rule 50. The decedent was a nonresident alien.

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