In Re Estate of Morris R. Silverman. Avrum Silverman v. Commissioner of Internal Revenue, Defendant-Respondent

FEINBERG, Circuit Judge:

This appeal by Avrum Silverman, executor of the estate of Morris R. Silver-man, from a decision of the Tax Court in favor of the Commissioner of Internal Revenue raises two questions: Was a transfer of a $10,000 whole life insurance policy by decedent to his son Avrum some six months before decedent’s death made in contemplation of death and, if so, what was the value of the interest transferred to be included in decedent’s gross estate? The Tax Court answered the first question in the affirmative and the second by including in decedent’s estate 88.71 per cent of the…