United States Court of Claims May 5, 1986, No. 184-84T (Levine v. United States)

OPINION

ON CROSS-MOTIONS FOR SUMMARY JUDGMENT

PHILIP R. MILLER, Judge:

I.

This is a suit for refund of $18,133.50 in estate taxes. The question presented is whether there should be included in the decedent’s gross estate, as transfers in contemplation of death within the scope of Internal Revenue Code (I.R.C.