ESTATE OF DELANY v. COMMISSIONER

Docket No. 109861.

1 T.C. 781 (1943)

ESTATE OF CHARLES DELANY, DECEASED, HOWARD S. DELANY, ET AL., EXECUTORS, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated March 17, 1943.


Attorney(s) appearing for the Case

Frank A. Moorshead, Esq., for the petitioners.

Lewis S. Pendleton, Esq., for the respondent.


Respondent determined a deficiency in estate tax in the amount of $176,380.16. based upon a number of adjustments, some of which are not in controversy here. The issues for decision are whether or not certain gifts made by decedent during his lifetime to trustees for the benefit of his children and a gift made directly to his son constituted transfers intended to take effect in possession or enjoyment at death or were made in contemplation of death, within the meaning of...

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