Belyea's Estate v. Commissioner of Internal Revenue

HASTIE, Circuit Judge.

This is a petition for review of an estate tax decision of the Tax Court upholding the Commissioner’s determination that certain gifts made by decedent without qualification and without restriction on immediate full enjoyment by the donees were transfers in contemplation of death and, therefore, that their value was includible in decedent’s taxable estate.

Under Section 811 of the Internal Revenue Code the taxable estate of a decedent includes property so transferred that it comes within the following category:

“(c) Transfers in contemplation of, or taking effect at, death

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