ESTATE OF STEVENS v. COMMISSIONER

Docket No. 94063.

23 T.C.M. 921 (1964)

T.C. Memo. 1964-154

Estate of Julia I. Stevens, The Marine Trust Company of Western New York, Fred J. Inglehart and Irving A. Barrett, Executors v. Commissioner.

United States Tax Court.

Filed June 5, 1964.


Attorney(s) appearing for the Case

Gilbert J. Pedersen, Genesee Bldg., Buffalo, N. Y., for the petitioner. Philip Shurman, for the respondent.


Memorandum Opinion

WITHEY, Judge:

The respondent determined a deficiency in the petitioner's estate tax in the amount of $17,123.17.

The sole issue presented for our decision is the correctness of the respondent's action in determining that one-half the value of the assets comprising the corpus of a trust created under the will of Edgar B. Stevens, deceased, is includable in the gross estate of Julia I. Stevens under section 2033 of the Internal...

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