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ESTATE OF GROSSINGER v. C.I.R.

No. 111, Docket 83-4082.

723 F.2d 1057 (1983)

ESTATE OF Selig Allen GROSSINGER, Deceased, Joseph G. Blum, Executor, Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Second Circuit.

Decided December 14, 1983.

Attorney(s) appearing for the Case

Maurice H. Greenberger, Hutton & Solomon, New York City, for appellant.

Glenn L. Archer, Jr., Asst. Atty. Gen., Washington, D.C. (Michael L. Paup, Gary R. Allen, Lisa A. Prager, Tax Div., Dept. of Justice, Washington, D.C.), for appellee.

Before LUMBARD, OAKES and KEARSE, Circuit Judges.

OAKES, Circuit Judge:

This is an appeal from a judgment of the Tax Court, Jules G. Korner III, Judge, finding a deficiency as the result of the taxpayer's improper exclusion from the decedent's gross estate of the full fair market value of future payments due to a third party under certain instruments purporting to establish an indebtedness in the form of a gift or a trust. Estate of Grossinger v. Commissioner, T.C. Memo. 1982-393

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