ESTATE OF GILBERT v. COMMISSIONER

Docket No. 19344.

14 T.C. 349 (1950)

ESTATE OF JAMES GILBERT, DECEASED, CHARLOTTE K. GILBERT, EXECUTRIX, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated March 2, 1950.


Attorney(s) appearing for the Case

Alfred M. Schaffer, Esq., for the petitioner.

Rigmor O. Carlsen, Esq., for the respondent.


This proceeding involves a deficiency of $19,039.46 in estate tax. The issues for decision are whether the transfers by decedent to his wife of 437 shares of stock of the Gilbert Casing Co. in December, 1940, and January, 1941, were made in contemplation of death, or were transfers intended to take effect in possession or enjoyment at or after decedent's death within the provisions of section 811 (c) of the Internal Revenue Code....

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