BROWN v. COMMISSIONER

Docket No. 6578-66.

52 T.C. 50 (1969)

S. E. BROWN, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 8, 1969.


Attorney(s) appearing for the Case

Wentworth T. Durant and Ronald M. Mankoff, for the petitioner.

Roy E. Graham, for the respondent.


DAWSON, Judge:

Respondent determined a gift tax deficiency of $41,276.54 against petitioner for the year 1963. The ultimate issue for decision is whether petitioner made a gift of the value of the remainder interest in his half of community property upon his wife's death in 1963.

FINDINGS OF FACT

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

S. E. Brown (herein referred to as petitioner) resided in Amarillo, Tex., at the...

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