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ESTATE OF SHOEMAKER v. COMMISSIONER

Docket No. 10364-82.

47 T.C.M. 1462 (1984)

T.C. Memo. 1984-174

Estate of Guy S. Shoemaker, Deceased, Arthur F. Shoemaker and Joan S. Wilder, Executors v. Commissioner.

United States Tax Court.

Filed April 5, 1984.

Attorney(s) appearing for the Case

Alan Parsons, One West Church St., Elmira, N.Y., and James Young (specially recognized), for the petitioners. Barry Finkelstein, for the respondent.

Memorandum Findings of Fact and Opinion

WHITAKER, Judge:

The Commissioner determined a deficiency in estate tax in the amount of $10,644.58. Due to concessions by both parties, the sole issue is whether or not the value of approximately 94 acres of real property (the Gift Property) conveyed by the decedent, Guy S. Shoemaker, to his three children, Arthur F. Shoemaker, Joan S. Wilder and Patricia S. Story, in December 1976 was a gift in contemplation of death...

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