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ESTATE OF ROSENBLATT v. COMMISSIONER

Docket No. 2067-76.

37 T.C.M. 957 (1978)

T.C. Memo. 1978-225

Estate of Nancy E. Rosenblatt, Deceased, Joseph Rosenblatt, Trustee v. Commissioner.

United States Tax Court.

Filed June 19, 1978.

Attorney(s) appearing for the Case

Ralph H. Miller, 200 S. Main St., Salt Lake City, Utah and Howard S. Landa, J.D. Kearns Bldg., Salt Lake City, Utah, for the petitioner. Craig D. Platz, for the respondent.

Memorandum Opinion

FAY, Judge:

Respondent determined a deficiency of $16,319.65 in the Federal estate tax of the Estate of Nancy E. Rosenblatt. The issue presented is whether the value of the accumulated income and corpus of the Nancy E. Rosenblatt Trust (hereinafter referred to as the "trust property") is includible in the beneficiary-decedent's gross estate under either section 20331

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