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LIBBEY v. UNITED STATES

No. 32555.

147 F.Supp. 383 (1956)

Rose M. LIBBEY, etc., Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court N. D. California, S. D.

December 24, 1956.

Attorney(s) appearing for the Case

George Devine, Jr., and P. S. Labagh, San Francisco, Cal., for plaintiff.

Lloyd H. Burke, U. S. Atty., Lynn J. Gillard, Asst. U. S. Atty., San Francisco, Cal., for defendant.

GOODMAN, District Judge.

This cause presents a new problem in interpretation of the ever troublesome section 811(c) of the Internal Revenue Code of 1939, 26 U.S.C.A. § 811(c), declaring that the value of a decedent's gross estate shall include the value of all property of which he has at any time made a transfer intended to take effect in possession or enjoyment at death. The very narrow question tendered is whether...

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