Rhode Island Hospital Trust Company v. Commissioner of Internal Revenue

MAGRUDER, Chief Judge.'

This is a petition filed by Rhode Island Hospital Trust Company, as executor of the estate of the decedent Thomas E. Steere, seeking review of a decision of the Tax Court, 22 T.C. 79,’determining a deficiency in the estate tax of the said decedent. The Commissioner had assessed certain deficiencies against the estate, all of which deficiencies were settled by the parties at or before trial in the Tax Court. The sole issue now before us was first raised in the Commissioner’s answer. The question presented is whether the decedent as settlor of a., certain trust had at the…