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ESTATE OF FEDER v. COMMISSIONER

Docket No. 42216.

22 T.C. 30 (1954)

ESTATE OF ANNIE FEDER, JACK M. FEDER, EXECUTOR, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 12, 1954.

Attorney(s) appearing for the Case

Norman A. Eisner, Esq., for the petitioner.

Charles W. Nyquist, Esq., for the respondent.

OPINION.

RICE, Judge:

This proceeding involves an estate tax deficiency of $4,300.01 determined against the estate of Annie Feder (sometimes hereinafter referred to as decedent).

The sole issue is whether the estate is entitled to a deduction under section 812 (b) (3) of the Code1 of $30,000, which sum decedent held as trustee for her son and daughter at the time of her death, when no claim for such sum was filed...

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