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ESTATE OF PRUDOWSKY v. COMMISSIONER OF INTERNAL REVENUE

No. 71-1716.

465 F.2d 62 (1972)

ESTATE of Harry PRUDOWSKY, Deceased, Vivian Prudowsky, Administratrix, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided July 25, 1972.

Attorney(s) appearing for the Case

Gary B. Simon, Milwaukee, Wis., for petitioner-appellant; Levin, Blumenthal, Herz & Levin, Milwaukee, Wis., of counsel.

Scott P. Crampton, Asst. Atty. Gen., Meyer Rothwacks, William A. Friedlander, Michael L. Paup, Attys., Tax Div., Dept. of Justice, Washington, D. C., for respondent-appellee.

Before FAIRCHILD and SPRECHER, Circuit Judges, and CAMPBELL, Senior District Judge.

PER CURIAM.

At death decedent held assets as custodian for his minor children under the Wisconsin Uniform Gifts to Minors Act.2 Decedent had been donor of the assets. The tax court held3 the assets to be includible in decedent's estate under both sections 2036 and 2038(a)(1) of the 1954 Internal Revenue Code.4 The facts and reasoning are set forth in the tax court decision. We affirm...

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