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ESTATE OF COHN v. COMMISSIONER

Docket No. 195-77.

37 T.C.M. 1847 (1978)

T.C. Memo. 1978-462

Estate of Harold W. Cohn, Deceased, Steven D. Cohn and Michele Cohn Tocci, Executors v. Commissioner.

United States Tax Court.

Filed November 21, 1978.

Attorney(s) appearing for the Case

Herman Mark Harris, 201 E. 42nd St., New York, N.Y., for the petitioner. Arthur H. Boelter, for the respondent.

Memorandum Opinion

FEATHERSTON, Judge:

Respondent determined a deficiency in petitioner's Federal estate tax in the amount of $15,301.79. The issue for decision is whether the full value of an annuity which was paid to the executors of the estate of Harold W. Cohn by the New York State Employees Retirement System is includible in decedent's gross estate under section 2039.1

The facts have been stipulated.

Decedent...

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