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ESTATE OF MACMANUS v. COMMISSIONER

Docket No. 5457.

8 T.C. 330 (1947)

ESTATE OF THEODORE F. MACMANUS, DECEASED, UNION GUARDIAN TRUST COMPANY, EXECUTOR, DETROIT TRUST COMPANY, SUCCESSOR, ALICE H. MACMANUS, EXECUTOR AND JOHN R. MACMANUS, EXECUTOR, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated February 18, 1947.

Attorney(s) appearing for the Case

John J. Sloan, Esq., for the petitioner.

L. R. Bloomenthal, Esq., for the respondent.

The respondent determined a deficiency of $75,358.07 in the estate tax of the estate of Theodore F. MacManus, deceased.

The primary issue is whether or not the value of the corpus of the trusts created by Theodore F. MacManus for the benefit of his children is includible in his estate under the provisions of section 811 (c) or section 811 (d) of the Internal Revenue Code.

A secondary issue is the proper value of annuity contracts determined by the respondent...

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