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ESTATE OF GREEN v. COMMISSIONER

Docket No. 18993-82.

52 T.C.M. 800 (1986)

T.C. Memo. 1986-511

Estate of James P. Green, Deceased, Gladys A. Green, Executrix v. Commissioner.

United States Tax Court.

Filed October 20, 1986.

Attorney(s) appearing for the Case

Robert K. Dowd, 1725 One Dallas Centre, Dallas, Tex., for the petitioner. James W. Lessis, for the respondent.

Memorandum Findings of Fact and Opinion

SIMPSON, Judge:

The Commissioner determined a deficiency of $15,692.12 in the petitioner's estate tax. The issue for decision is whether gifts made by the decedent within 3 years before his death were made in contemplation of death within the meaning of section 2035 of the Internal Revenue Code of 1954.1

Findings of Fact

Some of the facts have been stipulated, and those...

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