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ESTATE OF REID v. COMMISSIONER

Docket No. 9215-76.

71 T.C. 816 (1979)

ESTATE OF RUTH T. REID, DECEASED, WALTER D. REID, INDEPENDENT EXECUTOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed February 15, 1979.

Attorney(s) appearing for the Case

Robert C. Johnson, Jr., and Robert C. Johnson, for the petitioner.

Robert M. Smith, for the respondent.

GOFFE, Judge:

The Commissioner determined a deficiency in petitioner's Federal estate tax in the amount of $299,619.92.

Due to concessions made by the parties, the issues for our decision are:

(1) Whether decedent, in connection with an irrevocable inter vivos trust she created in 1955, possessed at the date of her death a contingent right to designate who would possess or enjoy trust property and income, thereby causing the inclusion of such...

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