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ESTATE OF THOMSON v. COMMISSIONER

Docket Nos. 7482-70, 3539-71.

58 T.C. 880 (1972)

ESTATE OF JAMES L. THOMSON, DECEASED, HARTFORD NATIONAL BANK AND TRUST COMPANY AND A. LINDSAY THOMSON, CO-EXECUTORS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. ESTATE OF ADELAIDE L. THOMSON, DECEASED, THE CONNECTICUT BANK AND TRUST COMPANY AND A. LINDSAY THOMSON, CO-EXECUTORS, PETITIONERS. v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed August 23, 1972.

Attorney(s) appearing for the Case

John M. Donahue and Elliott C. Miller, for the petitioners.

Robert B. Dugan, for the respondent.

OPINION

RAUM, Judge:

The Commissioner determined a deficiency of $37,176.18 in the estate tax of the Estate of James L. Thomson and a deficiency of $80,156.68 in the estate tax of the Estate of Adelaide L. Thomson. The only issues remaining for decision are: (1) Whether trust income added to principal periodically from 1933 through 1966 was "transferred" to the trust after March 4, 1931, the effective date of section 2036, I.R.C. 1954, where the decedent...

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