Estate of Pauson

This is an appeal from an order of the superior court fixing an inheritance tax upon certain property transferred by the deceased, Frank Pauson, upon the ground that such transfer was made in contemplation of death. At the time of the transfer the decedent was seventy-eight years of age and in vigorous health. He consulted an attorney, stating to the attorney that it was his intention to transfer all his property to a corporation to be organized under the name of Frank Pauson & Sons. Pursuant to this intention such corporation was organized, the deceased transferred to it about six hundred thousand dollars’ worth of property in consideration of the entire capital stock of the corporation, forty shares of which were issued to each of his four sons and twenty each to four daughters, and one share to the deceased. Three daughters who received twenty shares each had in 1913 received a gift of fifty thousand dollars each and the method of distributing the shares adopted was to equalize the amount received by each child. The shares were issued December 8, 1915. At the organization meeting of the corporation the deceased was elected president and voted a salary of twenty thousand dollars…