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ESTATE OF LEEDS v. COMMISSIONER

Docket Nos. 396-69, 397-69.

54 T.C. 781 (1970)

ESTATE OF RUDOLPH G. LEEDS, THE SECOND NATIONAL BANK OF RICHMOND, EXECUTOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT ESTATE OF FLORENCE SMITH LEEDS, THE SECOND NATIONAL BANK OF RICHMOND, EXECUTOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 16, 1970.

Attorney(s) appearing for the Case

Lester M. Ponder, Anton Dimitroff, and Edward W. Harris III, for the petitioners.

Bernard J. Boyle and Wayne I. Chertow, for the respondent.

TIETJENS, Judge:

The Commissioner determined deficiencies of $112,858.70 and $351,156.89 in the estate taxes of Estate of Rudolph G. Leeds and Estate of Florence Smith Leeds, respectively. We must decide whether, for the purpose of determining the amount of the marital deduction which may be allowed the Estate of Rudolph G. Leeds under section 2056, I.R.C. 1954,1 a bequest to his surviving wife abates for the payment of debts, administration...

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