ESTATE OF HUBBARD v. COMMISSIONER

Docket No. 52124.

26 T.C. 183 (1956)

ESTATE OF DEBE W. HUBBARD, THE MERCHANTS NATIONAL BANK OF MOBILE, EXECUTOR, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 27, 1956.


Attorney(s) appearing for the Case

C. A. L. Johnstone, Jr., Esq., for the petitioner.

W. Preston White, Jr., Esq., for the respondent.


Respondent determined a deficiency in estate tax of petitioner of $58,920.97. The two issues still in controversy are:

(1) Whether the value of an interest transferred in trust by decedent on January 26, 1932, is includible in her gross estate, and

(2) Whether executor's commissions on income received and distributed after decedent's death are an allowable deduction from decedent's gross estate.

Other issues raised by the pleadings have been settled...

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