The Commissioner has determined a deficiency of $17,016.75 in estate tax. The petitioners contend that there has been an overpayment in the amount of $36,692.02. The taxable year is 1942.
The sole issue is whether the taxpayer is entitled to a deduction from gross estate for residual charitable bequests under section 812 (d), Internal Revenue Code, where the will provided that the principal of the trust, which was subject to a life estate in decedent's widow, could...
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