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BUDD v. COMMISSIONER

Docket No. 5254-65.

49 T.C. 468 (1968)

ESTATE OF RALPH BUDD, DECEASED, CROCKER-CITIZENS NATIONAL BANK, EXECUTOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed February 7, 1968.

Attorney(s) appearing for the Case

Robert L. Thornburgh, for the petitioner.

Richard G. Daly, for the respondent.

OPINION

RAUM, Judge:

Respondent determined a deficiency in estate tax of $191,842. The question presented is whether certain powers retained by decedent over two trusts created by him required inclusion of the value of the trust property in his gross estate.1 The facts have been stipulated.

Ralph Budd, the decedent, died testate on February 2, 1962, a resident of California.

On March 21, 1932, decedent...

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