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ESTATE OF HOWARD v. COMMISSIONER

Docket No. 9208-87.

91 T.C. 329 (1988)

ESTATE OF ROSE D. HOWARD, DECEASED, ROGER W. A. HOWARD, VOLNEY E. HOWARD III, ALANSON L. HOWARD, ROBERT L. BRINER, TRUSTEES, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed August 23, 1988.

Attorney(s) appearing for the Case

William W. Summer, for the petitioner.

James W. Clark, for the respondent.

OPINION

TANNENWALD, Judge:

Respondent determined a deficiency in petitioner's Federal estate tax of $673,884.43. The issue for decision is whether a trust for which an election had been made under section 2056(b)(7)1 relating to the marital deduction for qualified terminable interest property, was a qualified terminable interest property trust so as to be includable in decedent's estate.2<...

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