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ESTATE OF FIELD v. COMMISSIONER

Docket No. 110585.

2 T.C. 21 (1943)

ESTATE OF LESTER FIELD, DECEASED, BARNETT HOLLANDER, TEMPORARY ADMINISTRATOR AND EXECUTOR, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated June 2, 1943.

Attorney(s) appearing for the Case

Sydney J. Schwartz, Esq., for the petitioner.

J. C. Maddox, Esq., for the respondent.

OPINION.

LEECH, Judge:

Respondent determined a deficiency of $4,782.82 in estate tax by, inter alia, including in the value of decedent's estate the entire value of the corpus of an inter vivos trust created by the petitioner's decedent in 1922. Petitioner asks a finding of an overpayment of $25,684.23. The propriety of that action of respondent is the only issue here. The estate tax return was filed with the collector for the second...

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