ESTATE OF HENDRY v. COMMISSIONER

Docket No. 8605-72.

62 T.C. 861 (1974)

ESTATE OF FRANCIS M. HENDRY, DECEASED, FIRST NATIONAL BANK OF TAMPA, EXECUTOR, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed September 24, 1974.


Attorney(s) appearing for the Case

William O.E. Henry and Michael J. Canan, for the petitioners.

Robert J. Shilliday, Jr., for the respondent.


DRENNEN, Judge:

Respondent determined a deficiency of $155,563.13 in the Federal estate tax liability of the Estate of Francis M. Hendry. The only issues for decision are: (1) Whether decedent retained such an interest in a 655-acre residence-ranch which he transferred to his wife in 1948 as to make the value thereof includable in his gross estate under section 2036(a)(1), I.R.C. 1954; and (2) whether the balance due, in the amount of $155,000, on three notes...

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