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ESTATE OF JALKUT v. COMMISSIONER

Docket No. 1770-89.

96 T.C. 675 (1991)

ESTATE OF LEE D. JALKUT, DECEASED, NATHAN M. GROSSMAN, EXECUTOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 29, 1991.

Attorney(s) appearing for the Case

John A. Simonetti, for the petitioner.

Vijay S. Rajan, for the respondent.

OPINION

NIMS, Chief Judge:

Respondent determined a deficiency in petitioner's Federal estate tax in the amount of $55,184.

The issue for decision is whether gift transfers made from the decedent's revocable trust within 3 years of his death are included in his gross estate pursuant to sections 2035(d)(2) and 2038(a)(1). (Unless otherwise indicated, section references are to sections of the Internal Revenue Code in effect as of the date of...

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