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ESTATE OF SAWADE v. C.I.R.

No. 85-1517.

795 F.2d 45 (1986)

ESTATE OF Myrtle M. SAWADE, Deceased, Louise C. (Dewey) Hornstein, Executor; Myrtle M. Sawade Revocable Living Trust (Executed May 17, 1977), Louise C. (Dewey) Hornstein, Trustee, as Transferee; Dinan E. Hornstein, Kathleen H. Rivero, and Louise C. (Dewey) Hornstein A/K/A Dewey C. Hornstein, as Transferees, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Eighth Circuit.

Decided June 25, 1986.

Attorney(s) appearing for the Case

John L. Sullivan, St. Louis, Mo., for appellants.

Lisa Prager, Dept. of Justice, Washington, D.C., for appellee.

Before HEANEY, ARNOLD and WOLLMAN, Circuit Judges.

WOLLMAN, Circuit Judge.

The Estate of Myrtle M. Sawade (Estate) appeals from a Tax Court judgment sustaining the Commissioner's determination of a deficiency in federal estate tax. We affirm.

I.

On May 17, 1977, Myrtle M. Sawade, as grantor, created a revocable living trust, appointing Louise C. Hornstein, her sister, successor trustee. Under the terms of the trust the successor trustee had the unqualified power to pay the debts and expenses of the...

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