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INGALLS v. C. I. R.

No. 9278.

336 F.2d 874 (1964)

Rachel H. INGALLS, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Fourth Circuit.

Decided September 14, 1964.

Attorney(s) appearing for the Case

Frank W. Rogers and Frank W. Rogers, Jr., Roanoke, Va. (Woods, Rogers, Muse & Walker, Roanoke, Va., on brief), for petitioner.

William A. Friedlander, Attorney, Department of Justice (Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson and Loring W. Post, Attorneys, Department of Justice, on brief), for respondent.

Before HAYNSWORTH and BOREMAN, Circuit Judges, and CRAVEN, District Judge.

PER CURIAM.

Is taxpayer entitled to restoration of all or any part of her gift tax specific exemption used against half of $150,000.00 of gifts made by her husband in 1957 when $75,000.00 was later determined by the Commissioner to have been made in contemplation of death? The Tax Court answered negatively. We agree.

Shortly before his death, Fay Ingalls made gifts totaling $150,000.00 to his four children and ten grandchildren. Under the provisions of Section...

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