Sullivan's Estate v. Commissioner of Internal Rev.

DENMAN, Chief Judge:

This is a petition to review a decision of the Tax Court which upheld the Commissioneris determination of deficiencies in the petitioner’s estate tax return. Two ques tions are presented for review: (A) Is the amount of a gift by two joint tenants, husband and wife, to their son, in contemplation of the husband’s death, includible in its entirety in the husband’s gross estate under 26 U.S.C. § 811(c), 26 U.S.C.A. § 811(c). 1 (B) Where two j-oint tenants agree to terminate a joint tenancy and henceforth hold the property as tenants in common and transfer each to the other…