This proceeding involves a deficiency in estate tax determined by respondent in the amount of $13,319.72. The sole issue is whether the gift by decedent to his wife, Laura D. Rosebault, of certain securities from their joint account on June 18, 1941, was a transfer in contemplation of death within the meaning of section 811 (c) of the Internal Revenue Code.
At the trial respondent conceded that upon proof of payment of New York State estate taxes by petitioner the...
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