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DE FOUCAUCOURT v. COMMISSIONER

Docket Nos. 7932-71, 7933-71.

62 T.C. 485 (1974)

ESTATE OF MARIE A. DE FOUCAUCOURT, DECEASED, LLOYD V. ALMIRALL AND MANUFACTURERS HANOVER TRUST COMPANY, EXECUTORS, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed July 8, 1974.

Attorney(s) appearing for the Case

Edward H. Hein and Charles M. Mitchell, for the petitioner.

Marion L. Weston, for the respondent.

WILES, Judge:

Respondent determined deficiencies in the Federal gift and estate taxes of petitioner as follows:

                                          Deficiency
  Gift tax (1963) ---------------------   $2,164.57
  Estate tax --------------------------   63,579.33

Several issues have been settled by the parties. The issues remaining for decision are:

(1) Whether principal commissions payable to trustees of an inter...

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