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ESTATE OF BRYAN v. COMMISSIONER

Docket No. 106494.

1 T.C.M. 1030 (1943)

Estate of John B. Bryan, Deceased, Security First National Bank of Los Angeles and Margaret Bryan Smith, Executors v. Commissioner.

United States Tax Court.

Entered April 30, 1943.

Attorney(s) appearing for the Case

Ralph W. Smith, Esq., 808 Bank of America Bldg., Los Angeles, Calif., for the petitioners. Frank T. Horner, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

Petitioners challenge the determination of an estate tax deficiency in the amount of $121,872.33 and claim to have overpaid the correct estate tax liability by the sum of $10,437.97. It is agreed that many of the issues raised by the pleadings may be settled in the recomputation under Rule 50. The principal questions to be decided are whether gifts made by the decedent to his daughter were transfers in contemplation of death...

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