ESTATE OF FRIZZELL v. COMMISSIONER

Docket No. 6704.

9 T.C. 979 (1947)

ESTATE OF JAMES E. FRIZZELL, DECEASED, ROY BURNS, E. A. JACKSON AND MARY GEORGE FRIZZELL, EXECUTORS, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated November 28, 1947.


Attorney(s) appearing for the Case

Joseph B. Brennan, Esq., for the petitioners.

Bernard D. Hathcock, Esq., for the respondent.


Respondent determined a deficiency in estate tax in the amount of $24,834.80.

Two questions are presented for decision: First, whether an inter vivos transfer in trust of stock was made in contemplation of death. Second, whether the entire corpus of the trust at the date of death is includible in the gross estate as the measure of estate tax.

Certain adjustments were not contested by petitioners. Petitioners abandoned one issue raised by their pleadings...

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