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SEATTLE TRUST AND SAVINGS BANK v. COMMISSIONER

Docket No. 27403.

22 T.C. 1214 (1954)

SEATTLE TRUST AND SAVINGS BANK, A CORPORATION, AS TRUSTEE UNDER TRUST AGREEMENTS DATED JULY 10, 1940, WITH NORTON CLAPP AND MARY CLAPP, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed September 21, 1954.

Attorney(s) appearing for the Case

W. E. Evenson, Esq., for the petitioner.

Wilford H. Payne, Esq., for the respondent.

OPINION.

OPPER, Judge:

Respondent determined a deficiency in Federal estate tax and penalty against petitioner as transferee of the estate of Mary Davis Joyce, deceased, in the respective amounts of $353,095.05 and $176,547.53. The penalty was waived by respondent at the hearing.

The sole issue is whether respondent properly included in decedent's gross estate, pursuant to section 811 (c) of the Internal Revenue Code of 1939, one-half of the...

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