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ESTATE OF McGAULEY v. COMMISSIONER

Docket No. 5705-71.

61 T.C. 350 (1973)

ESTATE OF LORRAINE A. McGAULEY, DECEASED, FREDERICK F. McGAULEY, TEMPORARY EXECUTOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 12, 1973.

Attorney(s) appearing for the Case

Michael J. Kenny, for the petitioner.

Harold B. Kushner and Ronald A. Wagenheim, for the respondent.

OPINION

SIMPSON, Judge:

The respondent determined a deficiency of $26,668.04 in the petitioner's estate tax. Due to concessions, the only issue remaining for decision is whether certain property was transferred to the decedent for purposes of the estate tax credit under section 2013, Internal Revenue Code of 1954,1 relating to prior transfers of property.

All of the facts have been stipulated, and those facts are...

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