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for distribution at that time was $368,050.76. This document
does not reflect the amount of cash or the fair market value of
cash equivalents as of March 10, 1992, the day of decedent's
death. We hold that the gross estate should be increased by
$91,010.91 to include cash equivalents not reported by petitioner
on its Federal estate tax return.
The final issue is whether the gross estate should include
$15,927.26 of accrued income payable to decedent at her death.
Section 20.2033-1(b), Estate Tax Regs., explicitly provides that
interest and dividends which have accrued as of the date of death
constitute a part of the gross estate.
During the period from January 1 to March 10, 1992, the
Marital Trust established under Andrew's will accrued income of
$15,927.26, which was payable to decedent and which was paid to
the Anna Soberdash Guardianship on April 29, 1992.
Petitioner appears to argue that the $15,927.26 should not
be included in the gross estate because it was also subject to
income taxation. Upon receipt of the $15,927.26, it was properly
subject to income taxation as income in respect of a decedent
under section 691(a). However, decedent's right to this income
at her death is an asset which must be included in the gross
estate under section 2033. See Estate of Earle v. Commissioner,
5 T.C. 991 (1945), affd. 157 F.2d 501 (6th Cir. 1946). We hold
that the accrued trust income of $15,927.26 should be included in
the gross estate.
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