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ESTATE OF WEBSTER v. COMMISSIONER

Docket Nos. 181-74, 8799-74.

65 T.C. 968 (1976)

ESTATE OF JANE DEP. WEBSTER, DECEASED, HENRY U. HARRIS, CHARLES F. HOVEY AND JAMES H. ORR, CO-EXECUTORS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed February 12, 1976.

Attorney(s) appearing for the Case

Carl J. Marold and Robert McDonough, for the petitioners.

Barry J. Laterman, for the respondent.

WILES, Judge:

Respondent determined a deficiency in decedent's estate tax of $7,379,278.53. Respondent also determined a gift tax deficiency of $4,641,913.22 for 1968. There are four issues before this Court:

(1) Whether decedent was transferor of the original corpus of a trust created in 1923;

(2) If decedent was, in fact, transferor of the corpus: (a) Whether, at her death, she had the power to terminate...

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