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ESTATE OF WILSON v. COMMISSIONER

Docket No. 19502.

13 T.C. 869 (1949)

ESTATE OF C. DUDLEY WILSON, THE TRENTON BANKING COMPANY, EXECUTOR, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated December 1, 1949.

Attorney(s) appearing for the Case

W. Arthur Campbell, Esq., and James O. Wynn, Esq., for the petitioner.

John T. Rogers, Esq., for the respondent.

The Commissioner determined a deficiency of $42,315.13 in estate tax. The issues for decision are whether transfers by the decedent to his two children at Christmas in 1943 and 1944, and transfers in December of 1937, 1938, 1940, and 1941 to trusts created in 1937 by the decedent for his two children were in contemplation of death, whether the transfers to the trusts were to take effect in possession or enjoyment at or after death, and whether the enjoyment of the trusts...

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