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WILSON v. COMMISSIONER

Docket Nos. 49836, 49837.

14 T.C.M. 299 (1955)

T.C. Memo. 1955-88

Betty Douglas Wilson, Transferee v. Commissioner. Virginia Douglas Dawson, Transferee v. Commissioner.

United States Tax Court.

Filed April 14, 1955.

Attorney(s) appearing for the Case

Alan E. Gray, Esq., 530 West 6th Street, Los Angeles, Calif., and Daniel W. Chapman, Esq., for the petitioners. Joseph G. White, Jr., Esq., for the respondent.

Memorandum Findings of Fact and Opinion

These consolidated transferee proceedings involve a deficiency in estate tax determined by the respondent against the Estate of Lloyd C. Douglas in the amount of $11,171.05. The petitioners have conceded their transferee liability if the respondent's determination of the deficiency is upheld.

The only issue is whether gifts in the amount of $41,000 made by decedent, Lloyd C. Douglas, in 1948 and 1949, within 3

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