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ESTATE OF BRYAN v. COMMISSIONER

Docket No. 2505-78.

74 T.C. 725 (1980)

ESTATE OF LOUISE D. BRYAN, DECEASED, CORINNE BRYAN MITSAK, PERSONAL REPRESENTATIVE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 21, 1980.

Attorney(s) appearing for the Case

Albert S. Barr III, Earl S. Wellschlager, and Edward S. Smith, for the petitioner.

Charles B. Zuravin, for the respondent.

OPINION

WILBUR, Judge:

Respondent determined a deficiency in decedent's Federal estate tax return in the amount of $15,712.80. The sole issue for decision is whether $60,000 received from the Client's Security Trust Fund for the Bar of Maryland is compensation "by insurance or otherwise" within the meaning of section 20541 so as to reduce the amount of theft loss deductible from the gross estate due to embezzlement.

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