Estate of Selig Allen Grossinger, Deceased, Joseph G. Blum v. Commissioner of Internal Revenue

OAKES, Circuit Judge:

This is an appeal from a judgment of the Tax Court, Jules G. Korner III, Judge, finding a deficiency as the result of the taxpayer’s improper exclusion from the decedent’s gross estate of the full fair market value of future payments due to a third party under certain instruments purporting to establish an indebtedness in the form of a gift or a trust. Estate of Grossinger v. Commissioner, T.C. Memo 1982-393 (July 14, 1982).

The facts were stipulated. The decedent, Selig A.. Grossinger (“Sandy” hereafter) died in 1972. His grandfather, Selig Grossinger, originally owned…