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E. NORMAN PETERSON MARITAL TRUST v. COMMISSIONER

Docket No. 26044-91.

102 T.C. 790 (1994)

E. NORMAN PETERSON MARITAL TRUST, CHEMICAL BANK, TRUSTEE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 28, 1994.

Attorney(s) appearing for the Case

Richard B. Covey and Michael I. Frankel, for petitioner.

Michael A. Menillo, for respondent.

OPINION

HAMBLEN, Chief Judge:

Respondent determined a deficiency in petitioner's Federal generation-skipping transfer (GST) tax in the amount of $810,925. Unless otherwise indicated, section references are to the Internal Revenue Code in effect as of the date of the transfers at issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

After concessions by petitioner,1 the issues for...

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