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ESTATE OF DU PONT v. COMMISSIONER

Docket No. 2926-70.

63 T.C. 746 (1975)

ESTATE OF WILLIAM DU PONT, JR., DECEASED, JEAN ELLEN DU PONT McCONNELL, WILLIAM S. POTTER, AND DELAWARE TRUST COMPANY, AS EXECUTORS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 31, 1975.

Attorney(s) appearing for the Case

Gordon W. Gerber and Leonard S. Togman, for the petitioners.

Albert Squire, for the respondent.

The Commissioner determined a deficiency in decedent's Federal estate tax in the amount of $7,203,109.99. Prior to the trial the parties reached agreement on all but three of the Commissioner's adjustments which pose essentially two principal issues for decision: (1) Does section 2036, I.R.C. 1954, require the inclusion in decedent's gross estate of the value of two parcels of improved real property (Hall, Inc., and Point Happy properties...

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