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ESTATE OF NICKEL v. COMMISSIONER

Docket No. 89927.

21 T.C.M. 300 (1962)

T.C. Memo. 1962-55

Estate of J. Leroy Nickel, Jr., Deceased, Gladys W. Nickel, Executrix, and Gladys W. Nickel, Surviving Wife v. Commissioner.

United States Tax Court.

Filed March 15, 1962.

Attorney(s) appearing for the Case

Czar S. Winters, Esq., 1101 Balfour Bldg., 351 California St., San Francisco, Calif., and Harold C. Faulkner, Esq., for the petitioners. Cyrus A. Johnson, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

OPPER, Judge:

Respondent has determined deficiencies in petitioners' income tax for the years 1955 and 1956 in the amounts of $82,977.36 and $65,537.68, respectively. The issues remaining for decision are (1) whether a transfer in 1955 of decedent's life interest in a portion of a trust in settlement of litigation was effective for tax purposes and, if so, (2) whether petitioners are entitled to deduct the value of...

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