Hiller Estate

SATTERTHWAITE, P. J.,

Two questions are presented in this appeal from the appraisement and assessment of inheritance tax: (1) Does the evidence sufficiently rebut the statutory presumption that decedent’s transfer of her residence realty to the names of herself, her son and the son’s wife, and the survivor of them, less than one year prior to her death, was a transfer taxable on the full value as one in contemplation of death? (2) If the presumption has been rebutted so that the entire value is not taxable, what fraction, one-third or one-half, is includible under the coownership provisions of…