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ESTATE OF ALLEN v. COMMISSIONER

Docket No. 85375.

39 T.C. 817 (1963)

ESTATE OF WILMAR MASON ALLEN, ERMA S. ALLEN, ADMINISTRATRIX, C.T.A., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed February 15, 1963.

Attorney(s) appearing for the Case

William S. Stewart, Esq., for the petitioner.

John L. Ridenour III, Esq., for the respondent.

OPINION.

DRENNEN, Judge:

Respondent has determined that there is due from petitioner a deficiency in estate tax in the amount of $18,520.36.

The issues for decision are:

(1) The value for estate tax purposes of benefits under a pension agreement entered into between Wilmar Mason Allen (hereafter called decedent) and his employer; and

(2) Whether petitioner is entitled to a marital deduction equal to the value of the interest...

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