Roger Estate

Adjudication by

Mims, J.,

The decedent died on October 15, 1979, having been born on December 21,1901.

*396Section 222 of the Inheritance and Estate Tax Act of 1961 provides:

Contemplation of Death — A transfer conforming to Section 221 (a), and made in contemplation of the death of the transferor, is subject to tax under this Act. A transfer shall not be deemed or held to have been made in contemplation of death if made more than two (2) years prior to the death of the transferor, but, unless shown to the contrary, shall be deemed to have been in contemplation of death if it is of a material part of…