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KATE FROMAN TRUST v. COMMISSIONER

Docket No. 3704-70.

58 T.C. 512 (1972)

KATE FROMAN TRUST, ADOLPH SIEVERS, AND SECURITY BANK AND TRUST COMPANY OF MT. CARMEL, CO-TRUSTEES, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed June 20, 1972.

Attorney(s) appearing for the Case

Addis E. Hull and Ronald I. Reicin, for the petitioners.

Lewis M. Porter, Jr., for the respondent.

SIMPSON, Judge:

The respondent determined that the petitioners are liable as transferees for a deficiency in the Federal estate tax of the Estate of Kate Froman in the amount of $56,710.28. The issue for decision is whether the fact that the trustees under a testamentary trust had certain discretionary powers with respect to the investment of property and the allocation of receipts between income and principal caused the value of a charitable remainder to be...

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