Estate of Zaiger v. Commissioner
United States Tax Court
1. Transfers by decedent's wife from a checking account held jointly with decedent without his knowledge were not gifts in contemplation of death. 2. Gifts of voting trust certificates within 3 years of date of death were not gifts in contemplation of death. 3. Value of shares of stock in closely held family corporations determined for gift tax and estate tax purposes.
1Opinion of the Court
Goffe, Judge:
The Commissioner determined deficiencies in petitioners’ Federal estate and gift taxes as follows:
Petitioner Docket No. Tax Year Deficiency Total deficiency
Estate of Louis Zaiger 4981-68 Estate 1964 $472,271.75
Estate of Louis Zaiger 5442-71 Gift 1947 $31.68
1948 20.20
1949 24.70
1950 20.98
1951 246.04
1952 101.74
1954 289.09
1956 423.03
1957 1,456.55
1958 675.00
1964 13,279.00 16,568.01
10,028.00 Gift ^ CO 05 Beatrice Zaiger- 5443-71
'46,680.00 56,708.00 lO CO 05
The cases were consolidated for trial, briefs, and opinion. The parties resolved many of the issues prior to trial. The issues…
2Cases cited5 opinions
- United States v. WellsSupreme Court of the United States · 1931
- City Bank Farmers Trust Co. v. McGowanSupreme Court of the United States · 1945
- Estate of Reynolds v. CommissionerUnited States Tax Court · 1970
- Estate of Hite v. CommissionerUnited States Tax Court · 1968
- Wilson v. Comm'rUnited States Tax Court · 1971
3Cited by24 opinions
- The Estate of Mary Frances Smith Bright, Deceased, by H. R. Bright, Independent v. United StatesCourt of Appeals for the Fifth Circuit · 1981
- Estate of Andrews v. CommissionerUnited States Tax Court · 1982
- Ward v. CommissionerUnited States Tax Court · 1986
- Foltz v. U.S. News & World Report, Inc.District Court, District of Columbia · 1987
- Estate of Green v. CommissionerUnited States Tax Court · 1975
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