ESTATE OF HONICKMAN v. COMMISSIONER

Docket No. 3660-69.

58 T.C. 132 (1972)

ESTATE OF MAURICE H. HONICKMAN, DECEASED, KATE HONICKMAN, HAROLD A. HONICKMAN AND GIRARD TRUST BANK, COEXECUTORS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 26, 1972.


Attorney(s) appearing for the Case

Patrick W. Kittredge, for the petitioners.

Mary Ann Hagan, for the respondent.


TANNENWALD, Judge:

Respondent determined a deficiency of $23,237.73 in the Federal estate tax of the Estate of Maurice H. Honickman. Due to concessions by both parties, the only two issues remaining for our consideration are:

(1) Whether the transfer of certain property in trust by the decedent within the 3 years preceding his death was made "in contemplation of death," as that term is used in section 2035,1 and

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