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ESTATE OF COLE v. COMMISSIONER

Docket Nos. 108285, 108283.

1 T.C.M. 405 (1943)

Estate of Haydn S. Cole, deceased, Wallace H. Cole, as Executor of Will of said Decedent v. Commissioner. Estate of Mary M. Cole, deceased, Wallace H. Cole, as Administrator v. Commissioner.

United States Tax Court.

Entered January 9, 1943.

Attorney(s) appearing for the Case

Ira C. Oehler, Esq., 143 Endicott Bldg., St. Paul, Minn., and Stan D. Donnelly, Esq., for the petitioners. Franklin F. Korell, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

The respondent determined deficiencies of $27,198.70 and $10,174.49 in the estate taxes of the estates of Haydn S. Cole and Mary M. Cole, respectively.

The issue common to both cases is whether or not the sums of $157,850 and $68,100 should be included in the gross estates of Haydn S. Cole and Mary M. Cole, respectively, such sums representing the fair market value, at the...

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