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ESTATE OF GILL v. COMMISSIONER

Docket No. 21286-80.

79 T.C. 437 (1982)

ESTATE OF MARGARET O. GILL, DECEASED, ROBIN G. STANFORD, INDEPENDENT EXECUTRIX, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 9, 1982.

Attorney(s) appearing for the Case

Dougal C. Pope, for the petitioner.

Thomas G. Norman, for the respondent.

OPINION

WILBUR, Judge:

Respondent determined a deficiency in petitioner's Federal estate tax of $34,637.57. The sole issue presented for our decision is whether a transfer made in contemplation of death prior to the passage of the Tax Reform Act of 1976 may be taxed under section 2035(a) as it existed prior to decedent's death which occurred after January 1, 1977.

All of the facts have been stipulated. The stipulation of facts

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