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ESTATE OF ENGEL v. COMMISSIONER

Docket No. 8347.

6 T.C.M. 70 (1947)

Estate of Bertha M. Engel, Deceased, Glenn F. Turnbull and William A. Engel, Executors v. Commissioner.

United States Tax Court.

Entered January 29, 1947.

Attorney(s) appearing for the Case

Charles A. Wagner, Esq., and Alfred W. Massnick, Esq., 1881 Nat'l Bank Bldg., Detroit 26, Mich., for the petitioners. Clarence E. Price, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

The Commissioner determined a deficiency of $13,370.76 in estate tax. The only issue for decision is whether inter vivos gifts which the decedent made to her children were made in contemplation of death.

Findings of Fact

The petitioners are the executors of the estate of Bertha M. Engel. The estate tax return was filed with the collector of internal revenue for the first district of Michigan.

Bertha...

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