Estate of Mona Bettin, Deceased. Fredric Bettin v. Commissioner of Internal Revenue

This is an appeal from a decision of the United States Tax Court. The sole issue for consideration in this appeal is whether the Tax Court correctly found that withdrawals by the petitioner of certain amounts from a joint bank account in the names of himself and the decedent did not constitute gifts from the decedent to himself.

Facts

The following facts are adopted substantially from the Tax Court’s Memorandum Opinion, filed April 24, 1974. Fredric Bet-tin, petitioner, is the nephew and executor of the estate of Mona E. Bettin, who died on September 24, 1967. Petitioner was a resident of Los…