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ESTATE OF PRATT v. COMMISSIONER

Docket No. 108988.

1 T.C.M. 627 (1943)

Estate of Carrie V. Pratt, deceased, Auguste G. Pratt and Stephen W. Pratt, Executors v. Commissioner.

United States Tax Court.

Entered February 17, 1943.

Attorney(s) appearing for the Case

Arthur Mattson, Esq., 1 Wall St., New York City, for the petitioner. James C. Maddox, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

Respondent has determined a deficiency in the estate tax liability of the Estate of Carrie V. Pratt in the sum of $121,974.90. Practically all of this deficiency results from respondent's inclusion in decedent's gross estate of the corpora of two trusts created by decedent in 1928 in the respective amounts of $173,602.47 and $510,771.40. As to the inclusion of these amounts in decedent's gross estate, the petition alleges...

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