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  5. 752 F.2d 1128 (1985)
 

EDWARD D. ROLLERT RESIDUARY TRUST, ETC. v. C.I.R.

No. 83-1613.

752 F.2d 1128 (1985)

EDWARD D. ROLLERT RESIDUARY TRUST, GENESEE MERCHANTS BANK AND TRUST COMPANY, Trustee, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided January 16, 1985.

Attorney(s) appearing for the Case

Webb F. Martin, Russell E. Bowers (Lead Counsel), Flint, Mich., Richard B. Covey, argued, New York City, for petitioner-appellant.

Fred T. Goldberg, Jr., Chief Counsel, Joel Gerber, Acting Chief Counsel, Internal Revenue Service, Glenn L. Archer, Jr. (Lead Counsel), Michael L. Paup, Tax Division, Dept. of Justice, Robert A. Bernstein, Robert S. Pomerance, argued, Washington, D.C., for respondent-appellee.

Before KENNEDY and WELLFORD, Circuit Judges, and WEICK, Senior Circuit Judge.

WEICK, Senior Circuit Judge.

Petitioner-Appellant, Edward D. Rollert Residuary Trust, Genesee Merchants Bank and Trust Company, Trustee, (Taxpayer), appeals from a judgment of the Tax Court determining deficiencies in Taxpayer's income tax for the years 1973, 1974 and 1975. This case presents a question of first impression in the Tax Court and in this circuit concerning the applicability and interaction of section 691 and sections 661 and 662 of the Internal Revenue...

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