Estate of Wilkinson v. Commissioner

OPINION.

ARUndell, Judge-.

The sole question involved in this proceeding is the proper amount of deduction allowable to the estate of the decedent for previously taxed property under section 812 (c) of the Internal Revenue Code.1 Petitioner takes the view that it is entitled to a deduction in an amount of $2,477,631.67 which'is the aggregate value of nineteen items of property which were included in the earlier estate, which items (or others exchanged therefor) are included in decedent’s estate at a higher valuation. Respondent, on the other hand, contends that a legatee who receives property…