ESTATE OF WOLF v. COMMISSIONER

Docket No. 58662.

29 T.C. 441 (1957)

ESTATE OF CHARLES B. WOLF, CHARLES S. WOLF, FRANCES G. WOLF, EXECUTORS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 12, 1957.


Attorney(s) appearing for the Case

Ralph F. Fisher, Esq., and Albert G. Blakey III, Esq., for the petitioner.

Stephen P. Cadden, Esq., for the respondent.


Respondent determined a deficiency in the estate tax of Charles B. Wolf in the amount of $55,714.21. As a result of various concessions and adjustments made by the parties the issues remaining in this litigation may be summarized by the following three questions:

1. Is the present value of amounts payable under a profit-sharing trust and certain retirement agreements includible in decedent's gross estate under any section of the Internal Revenue Code of 1939?

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