Estate of Muscle v. Director

NARAYANAN, J.T.C.

This is the court’s opinion in connection with the trial held in the above-captioned inheritance tax matter. The court finds that the defendant (“Director”) properly determined that the decedent’s reported gift of shares of stock in PSE & G to the decedent’s executrix made within six months of his death, was in contemplation of his death and therefore taxable pursuant to N.J.S.A. 54:34-1(e).

UNDISPUTED FACTS

Peter Muscle, a New Jersey resident, died testate on January 4, 2008, at the age of 88. About six (6) months prior to his death, in July 2007, he allegedly gifted Linda…