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FRANCES BIDDLE TRUST v. COMMISSIONER

Docket No. 112209.

3 T.C. 832 (1944)

FRANCES BIDDLE TRUST, SYDNEY G. BIDDLE AND FIDELITY-PHILADELPHIA TRUST COMPANY, TRUSTEES, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated May 15, 1944.

Attorney(s) appearing for the Case

Kenneth W. Gemmill, Esq., for the petitioners.

William D. Harris, Esq., for the respondent.

OPINION.

MELLOTT, Judge:

The petitioners, Sydney G. Biddle and Fidelity-Philadelphia Trust Co., contest respondent's determination that the trust1 of which they are trustees (Frances Biddle trust) is liable, as a transferee of property of the estate of Frances Biddle, for estate tax in the amount of $1,789.37.

The issues are:

(1) Whether the value of the corpus of...

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