Wright v. Commissioner
United States Board of Tax Appeals
1. Gifts by decedent to her daughters, the residuary legatees under her will made at about the same time, while decedent was suffering from the infirmity which resulted in her death, held, transfers in contemplation of death. 2. Value of McKesson & Robbins, Inc., stock held value established by stock exchange prices for similar shares on valuation dates, notwithstanding that such prices may have been due to concealments and misrepresentations subsequently discovered. 3. Fees…
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1. Gifts by decedent to her daughters, the residuary legatees under her will made at about the same time, while decedent was suffering from the infirmity which resulted in her death, held, transfers in contemplation of death. 2. Value of McKesson & Robbins, Inc., stock held value established by stock exchange prices for similar shares on valuation dates, notwithstanding that such prices may have been due to concealments and misrepresentations subsequently discovered. 3. Fees for attorneys and witnesses in present proceeding held deductible from gross estate.
1Opinion of the Court
*554OPINION.
Oppek:
Our findings of fact dispose of the first issue by the ultimate determination that the property in question was transferred in contemplation of death. We have arrived at that result because of our belief that petitioner has failed to produce convincing evidence that decedent’s compelling motive was associated with life rather than death. The transfers were made shortly after decedent’s will was executed and disposed of her property similarly and to the natural objects of her bounty. Rengsdorff v. McLaughlin (Dist. Ct., N. Dist. Calif., S. D.), 21 Fed. (2d) 177; Travelers Bank &…
2Cases cited3 opinions
- Ithaca Trust Co. v. United StatesSupreme Court of the United States · 1929
- Citizens National Trust & Savings Bank v. RileyCalifornia Court of Appeal · 1932
- Boyd v. WylySupreme Court of the United States · 1888
3Cited by19 opinions
- Horwith v. CommissionerUnited States Tax Court · 1979
- Browning v. CommissionerUnited States Tax Court · 1997
- Johnson v. CommissionerUnited States Tax Court · 1980
- Rooney v. CommissionerUnited States Tax Court · 1987
- Stillman v. CommissionerUnited States Tax Court · 1965
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