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ESTATE OF SINCLAIR v. COMMISSIONER

Docket No. 3667.

6 T.C. 1080 (1946)

ESTATE OF ARTHUR SINCLAIR, DECEASED, UNITED STATES TRUST COMPANY OF NEW YORK, EXECUTOR, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated May 20, 1946.

Attorney(s) appearing for the Case

Henry S. Hooker, Esq., John McG. Goodale, Esq., and Arnold Furst, Esq., for the petitioner.

Bernard J. Long, Esq., for the respondent.

OPINION.

SMITH, Judge:

This proceeding involves an estate tax deficiency of $68,643.74. The questions for our determination are whether there should be included in decedent's gross estate either the entire values or the remainder values of the corpora of two trusts which he created during his life, one on September 20, 1928, for the benefit of his wife and others, and the other on November 26, 1935, for the primary benefit of his daughter. Certain...

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