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ESTATE OF ABRAHAM v. C.I.R.

No. 04-1886.

408 F.3d 26 (2005)

ESTATE OF Ida ABRAHAM, Deceased; Donna M. Cawley and Diana A. Slater, Administratrixes, Petitioners, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent, Appellee.

United States Court of Appeals, First Circuit.

Decided May 25, 2005.

Attorney(s) appearing for the Case

Brendan J. Shea, for appellants.

Michael J. Haungs, Tax Division, Department of Justice, with whom Eileen J. O'Connor, Assistant Attorney General, and Jonathan S. Cohen, Tax Division, Department of Justice, were on brief, for appellee.

Before TORRUELLA, LYNCH, and Howard, Circuit Judges.

LYNCH, Circuit Judge.

This is an appeal from a Tax Court determination unfavorable to the estate of Ida Abraham (the Estate), brought by her two daughters as administratrixes. Applying 26 U.S.C. § 2036(a), the Tax Court concluded that the Estate had underreported the taxes due because the decedent had an interest in certain property purportedly transferred to her children by gift and purchase, that the purchase of the decedent's interests by the children were...

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