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ESTATE OF HENRY v. COMMISSIONER

Docket Nos. 2926-75, 2927-75.

69 T.C. 665 (1978)

ESTATE OF DOUGLAS HENRY, DECEASED, THIRD NATIONAL BANK, ET AL., CO-EXECUTORS, AND KATHRYN C. HENRY, SURVIVING WIFE, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT KATHRYN C. HENRY, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed February 6, 1978.

Attorney(s) appearing for the Case

Harlan Dodson, Harlan Dodson III, and Jack H. Putnam, Jr., for the petitioners.

John B. Harper, for the respondent.

FEATHERSTON, Judge:

Respondent determined a deficiency in the amount of $647,934.63 in petitioners' joint Federal income tax for 1971. Alternatively, respondent determined a deficiency in the amount of $699,640.83 in petitioner Kathryn C. Henry's Federal income tax for 1972.

The principal issue for decision is whether petitioner Kathryn C. Henry realized net income as a result of the payment of gift taxes by the trusts to which she had made gifts of...

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