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ESTATE OF SILVERMAN v. COMMISSIONER

Docket No. 2364-71.

61 T.C. 605 (1974)

ESTATE OF MAX SILVERMAN, DECEASED, BLANCHE S. SILVERMAN, EXECUTRIX, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed February 4, 1974.

Attorney(s) appearing for the Case

Irving B. Stewart, for the petitioner.

Ronald A. Wagenheim, for the respondent.

OPINION

SCOTT, Judge:

Respondent determined a deficiency in estate tax of petitioner in the amount of $4,193.85.

The issue for decision is whether the proceeds of two contracts, providing that upon their maturity date they were exchangeable for contracts providing for an annuity or annuities as selected by the owner from certain annuity options which had been purchased by a qualified pension trust established by the employer of Max Silverman...

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