Bradley v. Smith

WOODWARD, District Judge.

The question presented by this record is whether or not a gift made by the decedent, Charles E. Coffin, to his daughter, Carolyn *162Coffin Bradley, within two years of the death of the decedent, was made in contemplation of death within the meaning of Section 302(c) of the Revenue Act of 1926, as amended by Section 803 of the Revenue Act of 1932, 26 U.S.C.A.Int.Rev.Code, § 811(c). The estate tax on this gift was paid under protest, a claim for refund was filed and denied and suit was instituted in the District Court by decedent’s executors against the Collector of…