Estate of Carnall v. Commissioner

OPINION.

Mulroney, Judge:

The only question in this case is the amount of property which was the subject of a transfer in decedent’s lifetime, that will be included in his gross estate under section 811 (c). Decedent and his wife held certain securities as tenants by the entireties, which securities had all been purchased originally with decedent’s own funds. In 1945 they transferred the securities from themselves as tenants by the entireties to themselves individually in equal shares. It is practically admitted the 1945 transfer was in contemplation of decedent’s death, which occurred in 1947.…