ESTATE OF HITE v. COMMISSIONER

Docket No. 3404-65.

49 T.C. 580 (1968)

ESTATE OF ROBERT W. HITE, SR., THE KENTUCKY TRUST COMPANY, ANNE HITE CORN, HELEN HITE SALLEE, CO-EXECUTORS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 5, 1968.


Attorney(s) appearing for the Case

Arthur W. Grafton, for the petitioners.

Meno W. Piliaris, for the respondent.


HOYT, Judge:

Respondent has determined a $11,538.32 deficiency in decedent's estate tax. The question for decision is whether two gifts totaling $84,803.60 were made by decedent in contemplation of death, within the meaning of section 2035, I.R.C. 1954. The parties have not conceded or settled any portion of the determined deficiency.

FINDINGS OF FACT

Some of the facts have been stipulated, are found accordingly, and are incorporated herein...

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