ESTATE OF BELL v. COMMISSIONER

Docket No. 7973-74.

66 T.C. 729 (1976)

ESTATE OF NATHALIE F. BELL, DECEASED, GILBERT H. OSGOOD AND CHICAGO TITLE AND TRUST CO., EXECUTORS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 22, 1976.


Attorney(s) appearing for the Case

Rollin C. Huggins, Jr., and Alan R. Brodie, for the petitioners.

Seymour I. Sherman, for the respondent.


OPINION

FEATHERSTON, Judge:

Respondent determined a deficiency of $31,609.69 in the Federal estate tax of the Estate of Nathalie F. Bell. Two issues are presented for decision:

(1) Whether the value of assets transferred by decedent to a trust of which she was a cotrustee are includable in her gross estate pursuant to section 2036(a)(2)1 or 2038.

(2) If such assets are includable in decedent's gross estate...

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