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ESTATE OF LINEBERGER v. COMMISSIONER

Docket No. 36217.

13 T.C.M. 252 (1954)

Estate of A. C. Lineberger, Deceased, J. Harold Lineberger, Executor, v. Commissioner.

United States Tax Court.

Entered March 26, 1954.

Attorney(s) appearing for the Case

Leon L. Rice, Jr., Esq., W. P. Sandridge, Esq., and C. W. Womble, Esq., for the petitioner. Newman A. Townsend, Jr., Esq., for the respondent.

Memorandum Findings of Fact and Opinion

TIETJENS, Judge:

The respondent determined a deficiency in estate tax of $625,504.63. The only question for our determination is whether the transfers of property made by the decedent, A. C. Lineberger, in each of the years between 1935 and 1947 were made in contemplation of death within the meaning of section 811 (c) of the Internal Revenue Code. Certain subsidiary matters dependent on the above question will be settled...

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