Mueller Estate v. Transfer Inheritance Tax Bureau, Division of Taxation

CRABTREE, J.T.C.

This is a transfer inheritance tax case wherein plaintiffs seek review of the assessment of direct tax imposed by defendant with respect to (a) bequests made to decedent’s stepgrandchildren and (b) the devise of a legal life estate in decedent’s residence to a close friend. Plaintiffs claim that the bequests to stepgrandchildren should be taxed as transfers to Class A beneficiaries. Defendant taxed those bequests as transfers to Class D 1 beneficiaries. Plaintiff avers that no tax should be imposed upon the devise of the legal life estate as the beneficiary thereof made a…