Meyer v. United States

Amelia W. Leavitt conveyed real estate valued at $238,000 to her daughter, Sarah Leavitt Meyer, an only child, on October 7, 1919, and died, at the age of 64 years, on December 1, 1919.

When her husband, G. Howland Leavitt, who had duly qualified as executor, made return to the collector of internal revenue for Federal estate tax purposes, he reported this conveyance but did not include the value of that real estate in the estate subject to taxation, because, as he maintained, the conveyance, although made within two years of the decedent’s death, was not made in contemplation of death within…