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REPUBLIC NATIONAL BANK OF DALLAS v. COMMISSIONER

Docket No. 92189.

39 T.C. 85 (1962)

REPUBLIC NATIONAL BANK OF DALLAS, TRUSTEE, TRANSFEREE, ESTATE OF R. B. GEORGE, DECEASED, TRANSFEROR, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 12, 1962.

Attorney(s) appearing for the Case

L. E. Elliott, Esq., for the petitioner.

Roy E. Graham, Esq., for the respondent.

OPINION.

BLACK, Judge:

This proceeding involves a deficiency in Federal estate taxes in the amount of $60,808.60. In computing the amount of a charitable bequest, the Commissioner deducted administration expenses in the amount of $156,785.06 and thereby reduced the value of the charitable residue by this amount.

Petitioner's assignment of error is as follows:

4. The determination of the tax...

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