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ESTATE OF COHEN v. COMMISSIONER

Docket No. 21028-80.

79 T.C. 1015 (1982)

ESTATE OF ABRAHAM COHEN, DECEASED, MAURICE M. COHEN, WILLIAM P. COHEN AND NORMAN D. COHEN, EXECUTORS, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 20, 1982.

Attorney(s) appearing for the Case

David R. Andelman, J. Thomas Price, and Arnold R. Cutler, for the petitioners.

Barry J. Laterman, for the respondent.

RAUM, Judge:

The Commissioner determined a $435,158.78 deficiency in petitioner's Federal estate tax liability. After concessions, the sole issue remaining for decision is whether certain common and preferred shares in a Massachusetts realty trust, which the decedent gave outright during his lifetime to his children, grandchildren, and great-grandchildren, are includable in his estate under section 2036(a)(2) or section 2038(a)(1), I.R.C. 1954, by reason of...

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