Estate of Etta H. Weinberg - Page 2

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             interest over which the decedent had a general power of                  
             appointment on the date of her death.                                    
                  Throughout this opinion, all section references are to              
             the Internal Revenue Code as in effect on the date of                    
             decedent's death, and all Rule references are to the Tax                 
             Court Rules of Practice and Procedure.                                   

                                  FINDINGS OF FACT                                    
                  Some of the facts have been stipulated and are found                
             accordingly.  The stipulation and the accompanying exhibits              
             are incorporated herein.                                                 
                  The decedent died on December 15, 1992.  She was a                  
             resident of Philadelphia, Pennsylvania, at that time.  She               
             was also a widow.  Her husband, Mr. Bernard Weinberg, had                
             died in 1964.  She was survived by two children from her                 
             marriage to Mr. Weinberg, Mr. Paul S. Weinberg and                       
             Ms. Louise W. Brown.                                                     
                  On the date of her death, the decedent possessed a                  
             general power of appointment over the principal of a so-                 
             called marital deduction trust that had been created under               
             the last will and testament of her late husband (referred                
             to herein as Trust A).  Trust A held a 25.235-percent                    
             interest in a limited partnership, the Hill House Limited                
             Partnership (Hill House).                                                

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