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ESTATE OF PERIGNY v. COMMISSIONER

Docket No. 6679.

9 T.C. 782 (1947)

ESTATE OF MARGARET THAW CARNEGIE DE PERIGNY, FIDELITY TRUST COMPANY, EXECUTOR, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated October 28, 1947.

Attorney(s) appearing for the Case

Paul G. Rodewald, Esq., and Donald L. McCaskey, Esq., for the petitioner.

Stanley L. Drexler, Esq., for the respondent.

Involved in this proceeding is an estate tax deficiency of $287,001.61.

Certain issues having been eliminated by a stipulation of the parties and others reserved for settlement under Rule 50 recomputation, the sole remaining question is whether the agreed value of leasehold interests (99-year leases, exchangeable at the lessee's option for 999-year leases) in land situated in Kenya Colony, British East Africa, should be excluded from decedent's gross estate as "real...

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