Estate of Abraham v. Commissioner

LYNCH, Circuit Judge.

This is an appeal from a Tax Court determination unfavorable to the estate of Ida Abraham (the Estate), brought by her two daughters as administratrixes. Applying 26 U.S.C. § 2036(a), the Tax Court concluded that the Estate had underre-ported the taxes due because the decedent had an interest in certain property purportedly transferred to her children by gift and purchase, that the purchase of the decedent’s interests by the children were not bona fide sales for adequate and full consideration, and that the decedent retained rights in the income from the total property.…