Legal Opinion

Travelers Bank & Trust Co. v. Commissioner

United States Board of Tax Appeals

Decided October 10, 1933No. Docket No. 46686PublishedCited by 2 opinions

Transfers of stock by the decedent to his children five months prior to his death held to have been made in contemplation of death.

1Opinion of the Court

*93OPINION.

Seawell:

The issue relates only to the question of whether the gifts of stock made by the decedent on or about May 27, 1926, were made in contemplation of death within the meaning of section 302 (c) of the Revenue Act of 1926, set forth in the margin.1 We are not concerned with the gifts made prior thereto, but the respondent points out in his brief that they are of the same class.

It does not appear of record that the respondent ever determined from an investigation of the circumstances surrounding the transfers that the gifts were, in fact, made in contemplation of death. From the…

2Cases cited6 opinions

  1. United States v. WellsSupreme Court of the United States · 1931
  2. Heiner v. DonnanSupreme Court of the United States · 1932
  3. Lippincott v. CommissionerUnited States Board of Tax Appeals · 1933
  4. Garvan v. CommissionerUnited States Board of Tax Appeals · 1932
  5. Wheelock v. CommissionerUnited States Board of Tax Appeals · 1928

1 more not listed; retrieve them via the Exa API.

3Cited by2 opinions

  1. ESTATE OF McNAMARA v. COMMISSIONERS OF INTERNAL REVENUEUnited States Tax Court · 1981
  2. Travelers Bank & Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1933

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