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ESTATE OF LOWE v. COMMISSIONER

Docket No. 8692-73.

64 T.C. 663 (1975)

ESTATE OF JAMES R. LOWE, DECEASED, CROCKER NATIONAL BANK, JAMES R. LOWE, JR., AND MARGOT H. LOWE, CO-EXECUTORS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed July 28, 1975.

Attorney(s) appearing for the Case

Bruce M. Casey, Jr., Darrell E. Williams, Robert W. Morrison, and James B. Atkin, for the petitioners.

John Gigounas, for the respondent.

FORRESTER, Judge:

Respondent has determined a deficiency in estate tax in the amount of $2,077,686. Concessions having been made, the sole issue remaining for our decision is whether a certain transfer in trust made by decedent James R. Lowe within 3 years of his death is includable in the decedent's gross estate as a transfer in contemplation of death within the meaning of section 2035.1

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