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ESTATE OF NELSON v. COMMISSIONER

Docket No. 978-64.

47 T.C. 279 (1966)

ESTATE OF DONALD M. NELSON, DECEASED, LENA M. NELSON, EXECUTRIX, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 9, 1966.

Attorney(s) appearing for the Case

William E. Murray, Kent M. Klineman, and Thomas Mason Clyde, for the petitioner.

Rudolph J. Korbel and Stanley J. Goldberg, for the respondent.

TANNENWALD, Judge:

Respondent determined a deficiency in the estate tax of petitioner in the amount of $354,911.22.

The sole issue for our determination is what portion, if any, of an inter vivos trust set up for the benefit of the former wife of petitioner's decedent is includable in his estate.1

FINDINGS OF FACT

Some of the facts have been stipulated and are found accordingly.

Petitioner is the...

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