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  5. 51 T.C. 696 (1969)
 

ESTATE OF MARSHALL v. COMMISSIONER

Docket Nos. 147-67, 1178-68.

51 T.C. 696 (1969)

ESTATE OF DORA N. MARSHALL, DECEASED, CHARLES D. MARSHALL, AIKEN W. FISHER, AND CONTINENTAL BANK AND TRUST COMPANY, EXECUTORS, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed February 4, 1969.

Attorney(s) appearing for the Case

Paul G. Rodewald and James G. Park, for the petitioners.

Albert J. O'Connor, for the respondent.

FEATHERSTON, Judge:

Respondent determined deficiencies in petitioners' estate tax in docket No. 147-67 in the amount of $1,055,558.70 and in petitioners' gift tax in docket No. 1178-68 in the amount of $66,565.92, plus an addition to the gift tax of $16,641.48 under section 3612(d)(1) of the Internal Revenue Code of 1939.

Certain issues have been settled, and the addition to the gift tax has been conceded by respondent. The only issue remaining in the...

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