Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency of $406,655.51 in estate tax. The only issue is whether transfers to ten trusts were made in contemplation of death in the sense that they were substitutes for testamentary dispositions.
Findings of Fact
Carrie Loew Minzesheimer, the decedent, was born on January 27, 1871 and died on October 1, 1948.
Empire Corporation was a personal holding company in 1936...
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