Estate of Hofford v. Commissioner

OPINION.

Black, Judge:

As set out in our opening statement, the principal issue left for our consideration is whether the transfers by the decedent of the capital stock of Hofford Co. and the purchase of the annuity contract for the benefit of his wife were transfers includible in the decedent’s gross estate under section 811 (c) of the Internal Revenue Code. The material provisions of this section are set forth in the margin.1 Under these provisions any transfer made by a decedent during his lifetime is includible in his gross estate if it falls within any one of the three classifications…