ESTATE OF WELLS v. COMMISSIONER

Docket No. 1341-79.

42 T.C.M. 1305 (1981)

T.C. Memo. 1981-574

Estate of Gizella Wells, Deceased, David I. Wells, Executor v. Commissioner.

United States Tax Court.

Filed September 30, 1981.


Attorney(s) appearing for the Case

Remo Tinti, for the petitioner. Jack Joynt, for the respondent.


Memorandum Findings of Fact and Opinion

EKMAN, Judge:

Respondent determined a deficiency of $8,901.80 in petitioner's Federal estate tax. After concessions by the parties, the sole issue remaining for our decision is whether decedent retained any interest within the meaning of section 2036 (a)(1) when she created a trust on December 23, 1969.

Findings of Fact

Some of the facts have been stipulated and are so found. The stipulation of facts...

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