ESTATE OF HALPERN v. COMMISSIONER

Docket No. 5413-92.

70 T.C.M. 229 (1995)

T.C. Memo. 1995-352

Estate of Lillian L. Halpern, Deceased, Bernard M. Halpern and Irving J. Halpern, Executors v. Commissioner.

United States Tax Court.

Filed July 31, 1995.


Attorney(s) appearing for the Case

Richard I. Halpern and Dale Hershey, Pittsburgh, Pa., for the petitioner. Julia L. Wahl, for the respondent.


MEMORANDUM FINDINGS OF FACT AND OPINION

BEGHE, Judge:

Respondent determined a deficiency of $187,150 in petitioner's Federal estate tax. Respondent's amended answer increased the total deficiency to $517,595.

After concessions by both sides, the issues for decision are whether distributions during the years 1982 through 1988 from the marital deduction trust under the will of Julius Halpern (the marital trust) are included in the gross estate of his...

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