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ESTATE OF LEVY v. COMMISSIONER

Docket No. 2354-75.

70 T.C. 873 (1978)

ESTATE OF MILTON L. LEVY, DECEASED, JOHN LEVY, CO-EXECUTOR, JEFFREY R. LEVY, CO-EXECUTOR, IRIS LEVY, CO-EXECUTRIX, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 7, 1978.

Attorney(s) appearing for the Case

Harold N. Richmond, for the petitioner.

Patrick E. Whelan, for the respondent.

OPINION

GOFFE, Judge:

The Commissioner determined a deficiency in petitioner's Federal estate tax in the amount of $42,042.90.

Due to concessions by petitioner, the issues for our decision are:

(1) Whether section 20.2042-1(c)(6), Estate Tax Regs., is valid;

(2) If valid, whether section 20.2042-1(c)(6), Estate Tax Regs., as amended in 1974, applies retroactively to petitioner estate...

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