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ESTATE OF MUSCLE v. DIV. OF TAXATION

No. 001198-2010.

26 N.J. Tax 192 (2011)

ESTATE OF MUSCLE, BY ITS EXECUTRIX, LINDA JACKSON, PLAINTIFF, v. DIRECTOR, DIVISION OF TAXATION, DEFENDANT.

Tax Court of New Jersey.

November 30, 2011.

Attorney(s) appearing for the Case

Frederick W. Rose for plaintiff (Lindabury, McCormick, Estabrook & Cooper, P.C., attorneys).

Jill C. McNally for defendant (Paula T. Dow, Attorney General of New Jersey, attorney).

NARAYANAN, J.T.C.

This is the court's opinion in connection with the trial held in the above-captioned inheritance tax matter. The court finds that the defendant ("Director") properly determined that the decedent's reported gift of shares of stock in PSE & G to the decedent's executrix made within six months of his death, was in contemplation of his death and therefore taxable pursuant to N.J.S.A. 54:34-1(c).

UNDISPUTED FACTS

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