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ESTATE OF MARSHALL v. COMMISSIONER

Docket No. 19591.

16 T.C. 918 (1951)

ESTATE OF CHARLES D. MARSHALL, DECEASED, MELLON NATIONAL BANK AND TRUST COMPANY, DORA N. MARSHALL AND JOHN N. MARSHALL, EXECUTORS, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated April 27, 1951.

Attorney(s) appearing for the Case

Paul G. Rodewald, Esq., George M. Heinitsh, Jr., Esq., and Carl Cherin, Esq., for the petitioners.

J. Harrison Miller, Esq., for the respondent.

The Commissioner determined a deficiency of $2,404,842.79 in estate tax. The issue for decision is the amount, if any, which is to be included in the gross estate under section 811 (c) representing the value of retained reversionary interests in two trusts created by the decedent during his lifetime.

FINDINGS OF FACT.

Charles D. Marshall died on May 16, 1945, while residing in Pennsylvania. The estate tax return was filed with the collector of internal revenue...

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