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UNION COMMERCE BANK v. COMMISSIONER

Docket No. 93381.

39 T.C. 973 (1963)

THE UNION COMMERCE BANK, TRANSFEREE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 22, 1963.

Attorney(s) appearing for the Case

Warren E. Hacker, Esq., for the petitioner.

Clarence C. Roby, Esq., for the respondent.

OPINION.

ARUNDELL, Judge:

Respondent determined for assessment against petitioner the amount of $190,811.11, plus interest as provided by law, constituting petitioner's liability as trustee-transferee of property of Ethel M. Kolb, transferee of property of the estate of Justina C. Baker, Cleveland, Ohio, for a deficiency in estate tax.

The errors assigned are as follows:

(a) Respondent erred in determining that the decedent, Justina...

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