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ESTATE OF HOPPER v. COMMISSIONER

Dockets Nos. 38586, 38587, 38588.

22 T.C. 138 (1954)

ESTATE OF CHARLOTTE A. HOPPER, DECEASED, THE HARTFORD-CONNECTICUT TRUST COMPANY, EXECUTOR, ET AL., PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 26, 1954.

Attorney(s) appearing for the Case

Daniel B. Badger, Esq., for the petitioners.

Joseph Landis, Esq., for the respondent.

OPINION.

MURDOCK, Judge.

The Commissioner determined a deficiency of $255,549.84 in estate tax against the estate of the decedent and that the other two petitioners are liable one for all and the other for a part of that deficiency as transferees. The only two issues requiring decision are whether transfers in trust by the decedent in 1929 and direct gifts to her daughter during 1947, 1948, and 1949 were transfers in contemplation of death within...

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