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CITY BANK FARMERS TRUST COMPANY v. COMMISSIONER

Docket Nos. 13751, 13988.

12 T.C. 242 (1949)

CITY BANK FARMERS TRUST COMPANY, AS TRUSTEE UNDER AN AGREEMENT WITH STOCKWELL REYNOLDS DIAZ-ALBERTINI, DATED APRIL 17, 1914, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. ESTATE OF STOCKWELL REYNOLDS DIAZ-ALBERTINI, DECEASED (NORA REYNOLDS ALBERTINI VEITCH, FORMERLY NORA REYNOLDS ALBERTINI, EXECUTRIX), PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated February 28, 1949.

Attorney(s) appearing for the Case

John J. Smith, Esq., for the petitioner in Docket No. 13751.

J. Wesley Seward, Esq., for the petitioner in Docket No. 13988.

Conway N. Kitchen, Esq., for the respondent.

The Commissioner determined a deficiency of $53,129.91 in estate tax against the estate of Stockwell Reynolds Diaz-Albertini, petitioner in Docket No. 13988, and determined transferee liability for the deficiency against the City Bank Farmers Trust Co., trustee, petitioner in Docket No. 13751. Petitioners assail the inclusion in gross estate of the value of property which decedent transferred to a trust in 1914, reserving to himself...

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