ESTATE OF HOENIG v. COMMISSIONER

Docket No. 869-74.

66 T.C. 471 (1976)

ESTATE OF EDWARD E. HOENIG, MORGAN GUARANTY TRUST COMPANY OF NEW YORK AND SAMUEL S. ZUCKERBERG, EXECUTORS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 15, 1976.


Attorney(s) appearing for the Case

Thomas J. McGrath, for the petitioners.

Marion L. Westen and Theodore J. Kletnick, for the respondent.


FAY, Judge:

Respondent determined a deficiency of $108,583.54 in Federal estate taxes. We must decide if a legacy bequeathed to the decedent by his wife, Ethel G. Hoenig, and renounced by his executors subsequent to his death, is includable in his gross estate for purposes of the Federal estate tax.

FINDINGS OF FACT

Certain facts have been stipulated and are so found.

Edward E. Hoenig, the decedent, died a resident of New York, N.Y...

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