ESTATE OF LARZELERE v. COMMISSIONER

Docket No. 38497.

13 T.C.M. 455 (1954)

T. C. Memo. 1954-35

Estate of Elizabeth Wells Larzelere, The Florida National Bank of Jacksonville and L. J. Larzelere, Executors v. Commissioner.

United States Tax Court.

Filed May 12, 1954.


Attorney(s) appearing for the Case

Warren F. Wattles, Esq., Greenleaf Building, Jacksonville, Fla., for the petitioner. A. E. Carpens, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

The respondent determined a deficiency of $29,284.33 in estate tax.

The issues are: (1) whether the respondent erred in including in the gross estate the value of property transferred by decedent to a trust as a transfer made in contemplation of death; (2) in the alternative, is the value of a trust executed by the decedent's husband on the same date includible in the decedent's gross estate under the reciprocal trust...

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