In re the Estate of Ryle

Delehanty, S.

In this accounting proceeding the petition asks for the approval of an allowance to counsel for services in connection with a deficiency assessment of estate taxes made by the Internal Revenue Department. The parties agree that the amount proposed is reasonable, and so the court approves it.

The major controversy in the accounting proceeding concerns the measure of the liability for estate taxes and penalties thereon of the trustee of an inter vivos trust created by deceased some eight years before his death. Basically the trustee denies that the trust fund is chargeable with…