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ESTATE OF PENNEY v. COMMISSIONER

Docket No. 28813.

11 T.C.M. 379 (1952)

Estate of Samuel R. Penney, Deceased, Samuel R. Penney, Jr., Executor v. Commissioner.

United States Tax Court.

Entered April 17, 1952.

Attorney(s) appearing for the Case

Sidney W. Thaxter, Esq., for the petitioner. Lester H. Salter, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

The respondent has determined a deficiency of $11,079.97 in the petitioner's estate tax liability. The petitioner contests that part of the deficiency resulting from the inclusion of property transferred by an inter vivos trust in the decedent's gross estate as a transfer made in contemplation of death. Petitioner also contests the valuation assigned by the respondent to the capital stock of J. W. Penney & Sons...

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