First Western Bank & Trust Co. v. Commissioner

ARUndell, Judge:

Respondent determined for assessment against petitioner the amount of $49,698.63, plus interest as provided by law, as constituting petitioner’s liability as transferee and trustee of property of the estate of William P. Baker, deceased. Petitioner contests the entire determination. Errors have been assigned from (a) to (1). The assignments are grouped and summarized as follows:

1. Respondent erroneously included in the decedent’s gross estate the undistributed corpus of an inter vivos trust dated September 12, 1941;

2. Respondent’s determination is barred by the statute of…