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ESTATE OF DUCHARME v. COMMISSIONER

Docket No. 7055.

7 T.C. 705 (1946)

ESTATE OF CHARLES B. DUCHARME, DETROIT TRUST COMPANY, BY CONSOLIDATION WITH UNION GUARDIAN TRUST COMPANY, EXECUTOR, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated September 10, 1946.

Attorney(s) appearing for the Case

L. A. Masselink, Esq., and U. George Krapfel, Esq., for the petitioner.

Philip M. Clark, Esq., for the respondent.

Respondent has determined a deficiency in estate tax in the amount of $64,286.70. Respondent has conceded one issue. The remaining questions for our decision are, (1) whether all or any part of the corpus of a trust created by decedent on June 19, 1928, is properly includible in decedent's gross estate under section 811 (d) (2) of the Internal Revenue Code, and (2) whether one-half the corpus of a trust created by decedent's mother...

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