ESTATE OF DINELL v. COMMISSIONER

Docket No. 3695-69.

58 T.C. 73 (1972)

ESTATE OF JUDITH C. DINELL, DECEASED, FIRST NATIONAL CITY BANK, JUDY NAN HACOHEN AND TOM DINELL, EXECUTORS, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 17, 1972.


Attorney(s) appearing for the Case

George G. Vest and Dorrance Sexton, Jr., for the petitioners.

Jay S. Hamelburg, for the respondent.


ATKINS, Judge:

The respondent determined a deficiency in estate tax in the amount of $22,536.83. The primary issue is whether the transfer made by the decedent to her two children of a reversionary interest in a trust created by the decedent was made by decedent in contemplation of death with the result that the value of such reversionary interest is to be included in her gross estate under the provisions of section 2035 of the Internal Revenue Code of 1954...

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