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LEVINE v. COMMISSIONER

Docket No. 5937-77.

38 T.C.M. 537 (1979)

T.C. Memo. 1979-118

Estate of Louis S. Levine, Mary S. Levine, Executrix v. Commissioner.

United States Tax Court.

Filed March 29, 1979.

Attorney(s) appearing for the Case

Donald G. Daiker, 1625 The Alameda, San Jose, Cal., for the petitioner. Gordon C. Cook, for the respondent.

Memorandum Findings of Fact and Opinion

FAY, Judge:

Respondent determined a deficiency in petitioner's estate tax and an addition to tax under section 6651(a)1 of $7,743 and $1,936, respectively.

Concessions having been made, the issue for decision is whether the decedent's transfer of two life insurance policies to his wife within three years of the date of his death was made in contemplation of death.

Findings...

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