Estate of Hunt v. Commissioner

OPINION.

HakRon, Judge:

The first question is whether inter vivos transfers of four contracts of life insurance by the decedent to his wife were transfers of property made in contemplation of death within the meaning of section 811 (c) of the Internal Revenue Code. Respondent contends that the entire proceeds of each of the four contracts of life insurance are includible in the decedent’s estate under section 811 (c) as gifts made in contemplation of death. We do not believe, however, that respondent is correct in this contention.

The contemplation of death provision of section 811 (c) of the…