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ESTATE OF HUMMEL v. COMMISSIONER

Docket No. 11560-77.

38 T.C.M. 1101 (1979)

T.C. Memo. 1979-283

Estate of Frederick E. Hummel, Deceased, Virginia National Bank/Richmond (Formerly Virginia Trust Co.), Executor v. Commissioner.

United States Tax Court.

Filed July 26, 1979.

Attorney(s) appearing for the Case

Frank W. Hardy, 510 United Virginia Bank Bldg., 23210, for the petitioner. Stephen M. Friedberg, for the respondent.

Memorandum Findings of Fact and Opinion

WILBUR, Judge:

Respondent determined a deficiency of $11,901.60 in petitioner's Federal estate tax. Due to concessions by petitioner, the only issue for decision is whether an inter vivos transfer of $50,000 in trust by decedent to provide for the education of his great grandson was made in contemplation of death within the meaning of section 2035.1

Petitioner claims an overpayment...

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