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ESTATE OF LITTLE v. COMMISSIONER

Docket No. 34590-83.

87 T.C. 599 (1986)

ESTATE OF JOHN RUSSELL LITTLE, DECEASED, CROCKER NATIONAL BANK, EXECUTOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed September 11, 1986.

Attorney(s) appearing for the Case

Neil F. Horton, for the petitioner.

William E. Bonano, for the respondent.

OPINION

FAY, Judge:

Respondent determined a deficiency of $191,087 in the Federal estate tax of the Estate of John Russell Little. The only issue is whether the value of assets of a trust of which John Russell Little was a beneficiary and the sole trustee is includable in his estate under section 2041.1

This case has been submitted under Rule 122. All of the facts have been stipulated and are found accordingly...

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