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ESTATE OF HALBACH v. COMMISSIONER

Docket No. 7099-76.

40 T.C.M. 952 (1980)

T.C. Memo. 1980-309

Estate of Helen Wodell Halbach, deceased, John Poinier, Executor v. Commissioner.

United States Tax Court.

Filed August 12, 1980.

Attorney(s) appearing for the Case

Wallace B. Liverance, Jr., Geoffrey J. O'Connor, J. Frederic Taylor and Thomas C. Crane, 31 Rockefeller Plaza, New York, N.Y. for the petitioner. Steven I. Klein and Bernard Wishnia, for the respondent.

Supplemental Memorandum Findings of Fact and Opinion

STERRETT, Judge:

By letter dated April 30, 1976 respondent determined a deficiency in estate tax due from petitioner in the amount of $9,619,033.53. This deficiency was claimed on the basis that decedent Helen Wodell Halbach's "Disclaimer and Renunciation" of her remainder in the testamentary trust established by her father was (1) a transfer (2) in contemplation of death, thereby includable in her estate...

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