Estate of Martin v. Commissioner

OPINION.

HaeRon, Judgé:

The Commissioner determined in his deficiency notice (a) that the decedent had a vested remainder interest in one-eighteenth of the trust corpus, after the life estate of J. Sergeant Price, Jr., having a value at the time of decedent’s death of $213,828.73, and (b) a vested interest in one-ninth of the trust corpus, after the life estate of his mother, Elizabeth Price Martin, having a value at the time of decedent’s death' of $561,119.80, and that these interests are includible in decedent’s gross estate under section 811 (a) of the 1939 Code. Both of these…