ESTATE OF ROSENBERG v. COMMISSIONER

Docket No. 20654-84.

86 T.C. 980 (1986)

ESTATE OF FREDERICK ROSENBERG, DECEASED, PETER D. ROSENBERG, COEXECUTOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 19, 1986.


Attorney(s) appearing for the Case

Peter D. Rosenberg, for the petitioner.

Warren P. Simonsen, for the respondent.


OPINION

RAUM, Judge:

The Commissioner determined a $19,724 estate tax deficiency in respect of the Estate of Frederick Rosenberg, who died in 1980. After concessions, two issues remain in dispute: first, whether a $25,000 payment to decedent's son Peter pursuant to a retirement plan covering the decedent is includable in the decedent's gross estate under section 2039, I.R.C. 1954; and second, whether the first $3,000 of gifts by the decedent to Peter...

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