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ESTATE OF WILLIAMS v. COMMISSIONER

Docket No. 6194-72.

62 T.C. 400 (1974)

ESTATE OF CLARENCE A. WILLIAMS, DECEASED, WILLIAM E. NODINE, ADMINISTRATOR, D.B.N. C.T.A., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed June 25, 1974.

Attorney(s) appearing for the Case

Edward S. Wunsch, for the petitioner.

James C. Lynch, for the respondent.

DRENNEN, Judge:

Respondent determined a deficiency in Federal estate tax for the Estate of Clarence A. Williams in the amount of $115,821.54. The issues before the Court are whether, at the time of his death, Clarence A. Williams had a vested interest in either (1) a portion of the corpus of a testamentary trust established by his uncle or (2) the income from a portion of the corpus of the trust, which is includable in his gross estate under section 2033, I...

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