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ESTATE OF MICHELSON v. COMMISSIONER

Docket No. 8857-77.

37 T.C.M. 1534 (1978)

T.C. Memo. 1978-371

Estate of Harry R. Michelson, Deceased, South Shore Bank (formerly South Shore National Bank) and Charles L. Michelson, Executors v. Commissioner.

United States Tax Court.

Filed September 18, 1978.

Attorney(s) appearing for the Case

John Henderson Linsley, 100 Federal St., Boston, Mass., for the petitioner. Barry J. Laterman, for the respondent.

Memorandum Findings of Fact and Opinion

RAUM, Judge:

The Commissioner determined a deficiency in petitioner's Federal estate tax in the amount of $48,138.21. After concessions, the only issue in dispute between the parties is the includability in the decedent's gross estate, under sections 2036 and 2038, I.R.C. 1954, of the value of 49 shares in the Michelson Realty Trust registered in the name of decedent's adult son.

Findings of Fact

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