ESTATE OF CUTTER v. COMMISSIONER

Docket No. 5647-71.

62 T.C. 351 (1974)

ESTATE OF FRED A. CUTTER, JOHN W. CUTTER AND PATRICIA COOLEY, CO-EXECUTORS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed June 20, 1974.


Attorney(s) appearing for the Case

David M. Bridges and John M. Mooney, for the petitioners.

Joyce Elaine Britt, for the respondent.


IRWIN, Judge:

Respondent determined a deficiency of $117,719 in the estate tax of the Estate of Fred A. Cutter.

Due to certain concessions made by the parties, the only issue remaining for our decision is whether the principal and accumulated income therefrom (or any part thereof) of eight trusts established by the decedent during his lifetime for the benefit of his grandchildren should be includable in his gross estate. This issue depends upon whether...

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