BELYEA'S ESTATE v. COMMISSIONER OF INT. REV.

No. 11036.

206 F.2d 262 (1953)

BELYEA'S ESTATE v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals, Third Circuit.

Decided August 7, 1953.


Attorney(s) appearing for the Case

Joseph C. Glavin, Jersey City, N. J., for petitioner.

Cecelia H. Goetz, Washington, D. C. (H. Brian Holland, Asst. Atty. Gen., Ellis N. Slack and L. W. Post, Special Assts. to the Atty. Gen., on the brief), for respondent.

Before BIGGS, Chief Judge, and STALEY and HASTIE, Circuit Judges.


HASTIE, Circuit Judge.

This is a petition for review of an estate tax decision of the Tax Court upholding the Commissioner's determination that certain gifts made by decedent without qualification and without restriction on immediate full enjoyment by the donees were transfers in contemplation of death and, therefore, that their value was includible in decedent's taxable estate.

Under Section 811 of the Internal Revenue Code the taxable estate of a decedent...

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