Luscomb v. Commissioner

A deficiency in an estate tax accruing during the year 1923 was entered by the Board of Tax Appeals. The petitioner seeks a review pursuant to the provisions of the Revenue Act of 1926 (chapter 27, §§ 1001-1003, 44 Stat. 9, 109, 110 [26 USCA §§ 1224-1226]). It was held that gifts made by the decedent were so made in contemplation of death, and an appropriate tax therefor was imposed. The deceased died at the age of 72 years on May 26, 1923. The gifts were made to his wife, daughter and son on January 31, 1923, and March 27, 1923, amounting' in all to $421,200. At the time of these gifts, he…