ESTATE OF BABBITT v. COMMISSIONER

Docket No. 36998-84.

87 T.C. 1270 (1986)

ESTATE OF NONA H. BABBITT, DECEASED, PHYLLIS B. ANDERSON AND ALVIN E. BABBITT, INDEPENDENT EXECUTORS, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 4, 1986.


Attorney(s) appearing for the Case

Al Schulman, for the petitioner.

David B. Mora, for the respondent.


FEATHERSTON, Judge:

Respondent determined a deficiency in the amount of $45,557 in petitioner's estate tax. After concessions, the only issue for decision is whether decedent transferred during her lifetime 16 interests of $3,000 each in her residence to her 16 children and grandchildren which are includable in her gross estate under section 2035(a).1

FINDINGS OF FACT

Decedent Nona H. Babbitt (hereinafter decedent...

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