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ESTATE OF FLICKINGER v. COMMISSIONER

Docket No. 657.

2 T.C.M. 915 (1943)

Estate of Smith M. Flickinger, Deceased, Burt P. Flickinger and Glenn W. Flickinger, Executors v. Commissioner.

United States Tax Court.

Entered October 16, 1943.

Attorney(s) appearing for the Case

Ralph S. Ulsh, Esq., 505 Iroquois Bldg., Buffalo, N. Y., for the petitioners. Harold D. Thomas, Esq., for the respondent.

Memorandum Opinion

ARUNDELL, Judge:

The Commissioner determined a deficiency in estate tax in the sum of $68.865.38. The only issue presented for our decision is whether a gift in trust was a transfer intended to take effect in possession or enjoyment at or after the grantor's death within the meaning of section 811(c) of the Internal Revenue Code. The return was filed in the 28th district of New York.

[The Facts]

Petitioners are...

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