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ESTATE OF MAGNIN v. COMMISSIONER

Docket No. 24883-92.

71 T.C.M. 1856 (1996)

T.C. Memo. 1996-25.

Estate of Cyril I. Magnin, Deceased, Donald Isaac Magnin, Executor v. Commissioner.

United States Tax Court.

Filed January 24, 1996.

Attorney(s) appearing for the Case

Donald L. Feurzeig, Derek T. Knudsen, and John M. Youngquist, San Francisco, Calif., for the petitioner. Susan J. Adler and Rebecca T. Hill, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

RUWE, Judge:

Respondent determined a deficiency of $1,921,528 in petitioner's Federal estate tax. By amended answer, respondent has asserted an increase in the deficiency in petitioner's Federal estate tax in the amount of $157,685.

After concessions, the issues for decision are: (1) Whether decedent's 1971 transfers in trust with retained life estates are includable in decedent's gross estate, or whether they...

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