ESTATE OF EDWARD CARNALL v. COMMISSIONER

Docket No. 39556.

25 T.C. 654 (1955)

ESTATE OF EDWARD CARNALL, DECEASED, PROVIDENT TRUST COMPANY OF PHILADELPHIA AND EMILY H. CARNALL, EXECUTORS, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 28, 1955.


Attorney(s) appearing for the Case

D. Alexander Wieland, Esq., for the petitioners.

Edward Pesin, Esq., for the respondent.


The Commissioner determined a deficiency in estate tax in the amount of $10,630.77. Certain adjustments are not contested. The sole issue is whether the entire value of securities transferred in 1945 by the decedent and his wife from themselves as tenants by the entireties to themselves individually in equal shares is includible in the estate of the deceased husband, or merely one-half.

FINDINGS OF FACT.

All the facts have been stipulated and are so found...

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