United States Tax Court December 4, 1986, Docket No. 36998-84 (Estate of Babbitt v. Commissioner)

lead-opinion

FEATHERSTON, Judge:

Respondent determined a deficiency in the amount of $45,557 in petitioner’s estate tax. After concessions, the only issue for decision is whether decedent transferred during her lifetime 16 interests of $3,000 each in her residence to her 16 children and grandchildren which are includable in her gross estate under section 2035(a).1

FINDINGS OF FACT

Decedent Nona H.