ESTATE OF SACHS v. COMMISSIONER

Docket No. 9823-84.

88 T.C. 769 (1987)

ESTATE OF SAMUEL C. SACHS, DECEASED, STEPHEN C. SACHS, SOPHIA R. SACHS, COEXECUTORS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 6, 1987.


Attorney(s) appearing for the Case

Jerome W. Sandweiss and Mark Z. Schraier, for the petitioners.

Steven W. LaBounty, for the respondent.


OPINION

COHEN, Judge:

Respondent determined a deficiency of $516,365.63 in petitioners' Federal estate tax. In an amendment to answer, respondent also asserted an additional deficiency of $58,678.62. The issues for decision are: (1) Whether gift tax paid by the donees of net gifts made within 3 years of decedent's death is includable in decedent's gross estate under section 2035(c);1 (2) whether petitioners are entitled...

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