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ESTATE OF EDMONDS v. COMMISSIONER

Docket No. 10164-75.

72 T.C. 970 (1979)

ESTATE OF DEAN S. EDMONDS, DECEASED, BANK OF NEW YORK, EXECUTOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed August 29, 1979.

Attorney(s) appearing for the Case

Lawrence T. Warble, for the petitioner.

L. William Fishman, Stanley J. Goldberg, and Michael A. Zimmerman, for the respondent.

WILBUR, Judge:

Respondent determined a deficiency of $826,270.87 in petitioner's estate tax. Concessions having been made by the parties, the issues remaining for decision are:

(1) Whether the value of the portion of the principal of an inter vivos trust created by an indenture dated March 25, 1960, which is attributable to contributions by the decedent is includable in the decedent's gross estate;

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