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ESTATE OF EMANUEL v. COMMISSIONER

Docket No. 11435.

9 T.C. 779 (1947)

ESTATE OF EMMA H. EMANUEL, DECEASED, EDWARD CORNELL EMANUEL AND LOUIS E. VOIGT, EXECUTORS, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated October 28, 1947.

Attorney(s) appearing for the Case

William Wallace Booth, Esq., and Thomas J. McManus, Esq., for the petitioners.

George C. Lea, Esq., for the respondent.

OPINION.

OPPER, Judge:

The deficiency in controversy is in Federal estate tax in the amount of $2,701.02. The sole contested issue is whether four bank deposits placed in trust by decedent during her life are to be considered "property subject to general claims" for the purpose of determining the allowance for previously taxed property under section 812 (c), Internal Revenue Code. All of the facts have been stipulated and are hereby found accordingly...

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