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ESTATE OF COULTER v. COMMISSIONER

Docket No. 3821.

7 T.C. 1280 (1946)

ESTATE OF LELIA E. COULTER, DECEASED, JOEL WRIGHT COULTER, EXECUTOR, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated December 5, 1946.

Attorney(s) appearing for the Case

A. Calder Mackay, Esq., and Adam Y. Bennion, Esq., for the petitioner.

E. A. Tonjes, Esq., for the respondent.

TURNER, Judge:

The respondent determined an estate tax deficiency of $60,220.62. The issues presented are (1) whether the respondent erred in determining that a certain transfer of property made by decedent in 1920 as one of four grantors of a trust was made in contemplation of death or was intended to take effect in possession or enjoyment at or after death, within the meaning of section 811 (c) and (d) of the Internal...

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