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ESTATE OF ALEXANDER v. COMMISSIONER

Docket No. 3931-81.

81 T.C. 757 (1983)

ESTATE OF JOHN A. ALEXANDER, DARTMOUTH NATIONAL BANK OF HANOVER AND HERBERT CRAWFORD, COEXECUTORS, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed October 19, 1983.

Attorney(s) appearing for the Case

Daniel J. Connolly and Daniel F. Grossman, for the petitioners.

Barry J. Laterman, for the respondent.

RAUM, Judge:

The Commissioner determined a $164,974.70 Federal estate tax deficiency against the Estate of John A. Alexander (hereinafter petitioner or the estate). After concessions, the only issue remaining for decision is whether section 2036(a)(2), I.R.C. 1954, requires inclusion in the estate of that portion of an inter vivos trust which may be traced to transfers made by the decedent, John A. Alexander, to a trust in which the trustee could accumulate...

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