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ESTATE OF MARSHALL v. COMMISSIONER

Docket No. 13725-82.

49 T.C.M. 1547 (1985)

T.C. Memo. 1985-249

Estate of Esther S. Marshall, deceased, Thomas C. Marshall, Jr., and Lindsay Greenplate, executors v. Commissioner.

United States Tax Court.

Filed May 28, 1985.

Attorney(s) appearing for the Case

Robert L. Lefton, P. O. Box 506, Wilmington, Del. and Charles M. Allmond, III, 1118 King St., Wilmington, Del., for the petitioners. David E. Gaston and Maureen C. Kopko, for the respondent.

Memorandum Findings of Fact and Opinion

SWIFT, Judge:

In a statutory notice dated May 7, 1982, respondent determined a deficiency of $62,144.90 in the Federal estate tax liability of the estate of Esther S. Marshall. After concessions, the issue to be decided is whether the value of trust property is includible in decedent's gross estate under section 2036.1

Findings of Fact

This case was submitted fully stipulated...

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