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ESTATE OF PEARSON v. COMMISSIONER

Docket No. 31932.

11 T.C.M. 296 (1952)

Estate of Marshall G. Pearson, Deceased, Chester Pearson, Administrator v. Commissioner.

United States Tax Court.

Entered April 3, 1952.

Attorney(s) appearing for the Case

Marion Hirschburg, Esq., 300½ Main St., Ames, Iowa, and Rex Gilchrist, Esq., for the petitioner. Everett E. Smith, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

TIETJENS, Judge:

The respondent determined a deficiency of $24,578.31 in estate tax of the estate of Marshall G. Pearson, Deceased.

The issue presented is whether respondent erred in including in the decedent's gross estate the value of property made the subject of inter vivos transfers by gift, based on his determination that the transfers were made in contemplation of death within the section 811 (c) of the...

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