ESTATE OF COCHRAN v. COMMISSIONER

Docket No. 11568.

9 T.C. 242 (1947)

ESTATE OF MARY V. COCHRAN, DECEASED, ELLA COCHRAN SLUDER AND ST. LOUIS UNION TRUST COMPANY, A CORPORATION, EXECUTORS, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated August 28, 1947.


Attorney(s) appearing for the Case

Harold C. Hanke, Esq., for the petititoners.

George E. Gibson, Esq., for the respondent.


The respondent has determined a deficiency of $30,629.27 in the estate tax of the decedent, Mary V. Cochran. The sole question for our consideration is whether there should be included in the gross estate, as a transfer intended to take effect in possession or enjoyment at or after death, under section 811 (c), Internal Revenue Code, the value of the corpus of a trust which the decedent created during her lifetime, and prior to March 3, 1931, reserving the income for life...

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