Estate of Cyril I. Magnin, Deceased, Donald Isaac Magnin, Executor - Page 17

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          1952, are as follows:                                                       

                  Fiscal Year Ending January 31                                       
          (In Thousands)                                                              
          1949         1950         1951         1952                                 
          Assets                  $452         $405         $385         $432         
          Earned surplus           120          103          127          148         
          Sales                    742          644          593          677         
          Net income                35            6           24           21         
                                       OPINION                                        

               The Internal Revenue Code imposes a Federal estate tax on              
          the transfer of the taxable estate of a decedent who is a citizen           
          or resident of the United States.  Secs. 2001 and 2002.  The                
          value of the gross estate includes the value of all property to             
          the extent of the decedent's interest therein on the date of                
          death.9  Sec. 2033.                                                         
               Section 2036(a) provides that a decedent's gross estate also           
          includes the value of all property interests transferred by a               
          decedent during his life in which the decedent has retained for             
          life the right to the possession, enjoyment, or income from the             
          property.  However, section 2036(a) does not apply when the                 
          property interest of the decedent was transferred pursuant to a             
          "bona fide sale for an adequate and full consideration in money             



          9The executor, however, may elect to value a decedent's                     
          property as of an alternate valuation date; i.e., 6 months after            
          death.  Sec. 2032.                                                          




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