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ESTATE OF HAMAR v. COMMISSIONER

Docket No. 69575.

19 T.C.M. 575 (1960)

T.C. Memo. 1960-107

Estate of Lottie Hamar, Deceased, Myron Hamar, Executor v. Commissioner.

United States Tax Court.

Filed May 27, 1960.

Attorney(s) appearing for the Case

Richard Katcher, Esq., B. F. Keith Building, Cleveland, Ohio, and Sheldon J. Gitelman, Esq., for the petitioner. Maurice B. Townsend, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

The Commissioner determined a deficiency of $27,314.42 in estate tax and an addition to tax in the amount of $13,657.211 under Sections 894(a) and 3612(d) (2), Internal Revenue Code of 1939.

The issues are:

1. Whether a gift of $20,000 made by the decedent to her son, Myron Hamar, on January 12, 1953, within three years prior to her death, was made in contemplation of death within...

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