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ESTATE OF HARTZELL v. COMMISSIONER

Docket No. 27300-92.

68 T.C.M. 1243 (1994)

T.C. Memo. 1994-576

Estate of Miriam H. Hartzell, Deceased, George William Hartzell, Executor v. Commissioner.

United States Tax Court.

Filed November 23, 1994.

Attorney(s) appearing for the Case

Wiley Dinsmore, for the petitioner. Sherri L. Feuer and James D. Hill, for the respondent.

Memorandum Opinion

FAY, Judge:

Respondent determined a deficiency in estate tax due from petitioner in the amount of $5,424,893.

After concessions by the parties,1 the sole issue for decision, simply stated, is whether the date of death value of certain assets distributed from a marital trust to Miriam H. Hartzell during her lifetime, and subsequently given to her family...

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