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ESTATE OF CHALMERS v. COMMISSIONER

Docket No. 4569-70.

31 T.C.M. 792 (1972)

T.C. Memo. 1972-158

Estate of Arthur A. Chalmers, Deceased, Harvey Chalmers, 2nd and Richard D. Kearns, Co-Executors v. Commissioner.

United States Tax Court.

Filed July 27, 1972.

Attorney(s) appearing for the Case

Jacob H. Herzog and William J. Polen, 11 North Pearl St., Albany, N.Y., for the petitioners. Rudolph J. Korbel and Barry Gordon, for the respondent.

Opinion

QUEALY, Judge:

In this proceeding the Commissioner has determined a deficiency in the estate tax of the petitioners in the amount of $394,542.44. The petitioners contest that determination. The sole question for decision is whether two inter vivos trusts created by the decedent, known as the "Cooper trust" and the "Mills trust" are includable in the taxable estate of the decedent under the provisions...

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