ESTATE OF JOACHIM v. COMMISSIONER

Docket No. 41637.

22 T.C. 875 (1954)

ESTATE OF LINA JOACHIM, DECEASED, RICHARD H. JOACHIM, BENEFICIARY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed July 14, 1954.


Attorney(s) appearing for the Case

Charles Meyer, Esq., and Rene Loeb, Esq., for the petitioner.

John J. O'Toole, Esq., for the respondent.


OPINION.

RAUM, Judge:

The respondent determined a deficiency of $35,213.19 in estate tax of the estate of Lina Joachim, hereinafter referred to as the decedent. The issue is whether the amount of $168,361.80, which represented the sole asset in her estate, was exempt from tax under section 863 (b) of the Internal Revenue Code, as moneys deposited with a bank by "or for" the decedent. All of the facts have been stipulated and are hereby found accordingly...

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