In re the Transfer Tax Upon the Estate of Sexauer

We are of opinion that, under the facts disclosed by this record, the petitioner’s wife, now deceased, took title to the property, the transfer tax upon which is the subject of this litigation, as an absolute conveyance, notwithstanding the fact that the proof submitted by petitioner is that he paid the consideration therefor and has since exercised over it acts of ownership. The petitioner claims to have taken the property in the name of his *589wife for business reasons. The facts before us do not justify a finding that a constructive trust existed in favor of the petitioner within the meaning…