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ESTATE OF VARDELL v. COMMISSIONER

Docket No. 75855.

35 T.C. 50 (1960)

ESTATE OF LELA BARRY VARDELL, DECEASED, FIRST NATIONAL BANK IN DALLAS, EXECUTOR, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 17, 1960.

Attorney(s) appearing for the Case

Henry C. Coke, Jr., Esq., James K. Rushing, Esq., and Leland E. Fiske, Esq., for the petitioner.

John P. Higgins, Esq., for the respondent.

The Commissioner has determined a deficiency in estate tax against the estate of Lela Barry Vardell of $873,279.44. The deficiency is due to the additions to gross estate as disclosed by the return of "Schedule G — Transfers $2,217,983.48." This adjustment is explained in the deficiency notice as follows:

It is determined the total value of trust assets was $4,119,582.99 as of the date of death. The proportionate value, 53.84% of this amount, or $2,217,983...

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