ESTATE OF THACHER v. COMMISSIONER

Docket No. 17382.

20 T.C. 474 (1953)

ESTATE OF FRANK W. THACHER, DECEASED, PROVIDENT TRUST COMPANY OF PHILADELPHIA, CATHARINE L. THACHER, FRANKLIN WILLIAM THACHER, JR., AND JOHN HOOVER THACHER, EXECUTORS, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated May 28, 1953.


Attorney(s) appearing for the Case

Thorpe Nesbit, Esq., Logan Morris, Esq., Henry F. Stockwell, Esq., and Hugh Satterlee, Esq., for the petitioners.

Brooks Fullerton, Esq., for the respondent.


Respondent has determined a deficiency in estate tax in the amount of $511,345. The issues presented are:

(1) Whether the value of the corpus of six irrevocable trusts created by decedent in 1922 and 1924 for the benefit of his five minor children and of his wife are includible in his gross estate as transfers made in contemplation of death within section 811 (c) of the Internal Revenue Code, and if so,

(2) Whether respondent erred in failing to eliminate...

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