- 12 - We are “not compelled to believe evidence which to it seems improbable, or to accept as true uncorroborated evidence of interested witnesses even though uncontradicted.” Marcella v. Commissioner, 222 F.2d 878, 883 (8th Cir. 1955), affg. a Memorandum Opinion of this Court. We hold that the property was not owned by a partnership between the decedent and Joseph S. Maniglia and that the Fam-Trust, Joseph S. Maniglia as trustee and the decedent as sole beneficiary, owned the property at the decedent’s death. Accordingly, respondent properly included the entire value of the property in the decedent’s gross estate. To reflect the foregoing, Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12
Last modified: May 25, 2011