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ESTATE OF LOEW v. COMMISSIONER

Docket No. 46448.

13 T.C.M. 760 (1954)

T. C. Memo. 1954-117

Estate of Carrie Loew Minzesheimer, Chemical Bank & Trust Company, Executor v. Commissioner.

United States Tax Court.

Filed July 30, 1954.

Attorney(s) appearing for the Case

Harry L. Brown, Esq., World Center Building, Washington, D. C., for the petitioner. John James O'Toole, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

The Commissioner determined a deficiency of $406,655.51 in estate tax. The only issue is whether transfers to ten trusts were made in contemplation of death in the sense that they were substitutes for testamentary dispositions.

Findings of Fact

Carrie Loew Minzesheimer, the decedent, was born on January 27, 1871 and died on October 1, 1948.

Empire Corporation was a personal holding company in 1936...

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