ESTATE OF POLLARD v. COMMISSIONER

Docket No. 5688-66.

52 T.C. 741 (1969)

ESTATE OF FRANCES R. POLLARD, HAROLD K. BURT, EXECUTOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed August 4, 1969.


Attorney(s) appearing for the Case

Remsen M. Kinne III, for the petitioner.

Rufus E. Stetson, Jr., for the respondent.


OPINION

RAUM, Judge:

The Commissioner determined a deficiency in estate tax in the amount of $4,736.61. The principal adjustment giving rise to that deficiency, and the only one in issue, raises the question whether the commuted value of a life estate in the decedent's property commencing at the decedent's death in favor of her surviving husband was deductible as a "claim" against her estate that was contracted "for an adequate and full consideration...

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