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ESTATE OF McINTOSH v. COMMISSIONER

Docket Nos. 51124, 51125, 51130.

25 T.C. 794 (1956)

ESTATE OF MARY LOIS K. McINTOSH, DECEASED, RUSSELL L. McINTOSH AND EMPIRE TRUST COMPANY, EXECUTORS, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. ESTATE OF MARY LOIS K. McINTOSH, DECEASED, RUSSELL L. McINTOSH AND ST. LOUIS UNION TRUST COMPANY, TRUSTEES AND TRANSFEREES, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. ESTATE OF MARY LOIS K. McINTOSH, DECEASED, EUGENE KILPATRICK PERRY, TRANSFEREE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed January 18, 1956.

Attorney(s) appearing for the Case

Arthur M. Conley, Esq., and Frederick Pope, Jr., Esq., for the petitioners in Docket Nos. 51124 and 51125.

Raymond A. Carter, Esq., and Sidney D. Rosoff, Esq., for the petitioner in Docket No. 51130.

James R. McGowan, Esq., for the respondent.

The Commissioner determined a deficiency of $254,759.76 in estate tax to be due from the estate of Mary Lois K. McIntosh. The same deficiency has been determined against the other petitioners as transferees.

The questions for decision are (1) whether the value of the corpus of a certain trust is includible in decedent's gross estate and (2) whether the full amount of $18,000 paid for the support of the decedent's husband during...

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