Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency of $3,461.67 in estate tax. The only issue for decision is whether the transfer by the decedent of his Pittsburgh residence to his son and daughter was made in contemplation of death.
Findings of Fact
The estate tax return was filed with the Collector of Internal Revenue for the twenty-third district of Pennsylvania.
The decedent lived for most of his life...
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