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ESTATE OF TALBOT v. COMMISSIONER

Docket No. 10811-80.

42 T.C.M. 1263 (1981)

T.C. Memo. 1981-560

Estate of C. Finley Talbot, Deceased, Charles Finley Talbot, Jr. and Ruth M. Talbot, Administrators v. Commissioner.

United States Tax Court.

Filed September 29, 1981.

Attorney(s) appearing for the Case

Jackson L. Boughner, 959 28th Ave. N. Naples, Fla., for the petitioner. David M. Kirsch, for the respondent.

Memorandum Findings of Fact and Opinion

STERRETT, Judge:

By statutory notice dated May 27, 1980 respondent determined a deficiency in estate tax due from petitioner in the amount of $77,788.20. The sole issue for our decision is whether stock transferred by decedent within 3 years of his death was transferred in contemplation of death within the meaning of section 2035, I.R.C. 1954.1

Findings of Fact

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