Gray v. Director, Division of Taxation

ANDRESINI, J.T.C.

This is the court’s opinion with respect to the parties’ cross-motions for summary judgment. Andrew Gray, III, Executor for the Estate of Beatrice Jochman (“Plaintiff’) contends that the inheritance tax for Ms. Joehman’s estate should not be based on the inclusion of the values of the Beatrice Jochman Unitrust and the Beatrice Jochman Residence Trust. The Director, Division of Taxation (“Director”) contends that the transfers were made in contemplation of death and are therefore subject to the inheritance tax. For the reasons set forth below, the court grants plaintiffs…