Foster v. Commissioner

OPINION.

Lansdon:

The respondent has asserted a deficiency in estate tax in the amount of $13,663.92. The only issue is whether certain transfers to three separate trusts about three years prior to the death of N. C. Foster were made in contemplation of death.

N. C. Foster was a resident of Fairchild, Wisconsin. For about 60 years he was actively engaged in the lumber business, in railway construction and other money making enterprises in which he amassed a substantial fortune. He died March 16, 1923, and was survived by seven children. Many years before his death he organized the N. C. Foster…