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ESTATE OF HALBACH v. COMMISSIONER

Docket No. 7099-76.

71 T.C. 141 (1978)

ESTATE OF HELEN WODELL HALBACH, DECEASED, JOHN POINIER, EXECUTOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed November 9, 1978.

Attorney(s) appearing for the Case

Coleman Burke, Wallace B. Liverance, Jr., Kenneth M. Hart, and Geoffrey J. O'Connor, for the petitioner.

Gerald J. O'Toole, for the respondent.

STERRETT, Judge:

Respondent, on April 30, 1976, determined a deficiency in petitioner's estate tax in the amount of $9,619,033.53.1 Due to a severance of the issues raised by petitioner, the sole question for our determination is whether the disclaimer made by Helen Wodell Halbach of her remainder interest in a trust corpus constituted a transfer of property within the meaning of section 2035, I.R.C. 1954.

FINDINGS OF FACT...

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