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ESTATE OF IVERSEN v. COMMISSIONER

Docket No. 8082-73.

65 T.C. 391 (1975)

ESTATE OF ROBERT F. IVERSEN, DECEASED, PITTSBURGH NATIONAL BANK, AGENT FOR JOHN D. IVERSEN, EXECUTOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed November 25, 1975.

Attorney(s) appearing for the Case

Robert J. Dodds III, for the petitioner.

David W. Otto, for the respondent.

OPINION

SCOTT, Judge:

Respondent determined a deficiency of $225,446,01 in the Federal estate tax of the Estate of Robert F. Iversen. The issues for decision are (1) whether any consideration in money or money's worth was received by decedent for the creation of a trust to secure payments to his former wife so that the value of the trust assets includable in the gross estate should be reduced by the value of such consideration under section 2043(a...

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