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ESTATE OF CARDEZA v. COMMISSIONER

Docket No. 327.

5 T.C. 202 (1945)

ESTATE OF CHARLOTTE D. M. CARDEZA, FIDELITY-PHILADELPHIA TRUST COMPANY AND THOMAS D. M. CARDEZA, EXECUTORS, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated June 11, 1945.

Attorney(s) appearing for the Case

William R. Spofford, Esq., H. Ober Hess, Esq., and J. Harry Wagner, Jr., Esq., for the petitioners.

Brooks Fullerton, Esq., for the respondent.

The respondent determined a deficiency of $2,345,759.09 in estate tax against the estate of Charlotte D. M. Cardeza, deceased.

The issues involved are (1) whether any amount is includible in the decedent's gross estate as property passing under a general power of appointment; (2) whether any part of the corpus of a trust created by the decedent's father is includible in the decedent's gross estate as intestate property inherited by her; (3) whether payments made by...

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