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ESTATE OF HURD v. COMMISSIONER

Docket No. 7443.

6 T.C. 819 (1946)

ESTATE OF EDWARD L. HURD, CHARLOTTE H. HURD, EXECUTRIX, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated April 25, 1946.

Attorney(s) appearing for the Case

Daniel A. Rush, Esq., for the petitioner.

A. J. McDowell, Esq., for the respondent.

This proceeding involves an estate tax deficiency in the amount of $7,843.58.

The only question for our determination is whether the value of the corpus of a trust created by the decedent in 1935 is includible in his gross estate under section 811 (c) or section 811 (d) (2) of the Internal Revenue Code.

The other issues raised by the petition have been settled by the stipulation of facts.

FINDINGS OF FACT.

Part of the facts have been stipulated...

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