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ESTATE OF CUTCHEON v. COMMISSIONER

Docket Nos. 110324, 110325.

3 T.C. 636 (1944)

ESTATE OF FRANKLIN W. M. CUTCHEON, LYMAN RHOADES, ROBERT MUNRO FERGUSON AND JOHN B. MARSH, AS TRUSTEES AND TRANSFEREES, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. ESTATE OF FRANKLIN W. M. CUTCHEON, SARAH F. CUTCHEON, TRANSFEREE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated April 17, 1944.

Attorney(s) appearing for the Case

Carter T. Louthan, Esq., for the petitioners.

Conway Kitchen, Esq., for the respondent.

OPINION.

OPPER, Judge.

These are estate tax proceedings. A deficiency in the amount of $96,512.44 was determined against the respective petitioners as transferees of the estate of decedent, Franklin W. M. Cutcheon, resulting from the inclusion in the gross estate of the entire corpus of four trusts created by him during his lifetime. The estate tax return was filed with the collector for the first district of New York.

The stipulated facts...

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