When transfers are made with the advice of a lawyer or tax counselor in connection with a complete estate plan without other life-related motivation, the transfers are made in contemplation of death. Estate of Carnall v. Commissioner, 25 T.C. 654 (1955). It is apparent, however, that Mr. Lidbury made the gifts of 1973 and 1974 without the knowledge of his attorney.

When transfers are made with the advice of a lawyer or tax counselor in connection with a complete estate plan without other life-related motivation, the transfers are made in contemplation of death. Estate of Carnall v. Commissioner, 25 T.C. 654 (1955). It is apparent, however, that Mr. Lidbury made the gifts of 1973 and 1974 without the knowledge of his attorney.

That a Missouri estate of entirety is not recognized as a separate entity under the Income Tax Law, see Daniel Upthegrove, 33 B.T.A 952. See also Estate of A. Carl Borner, 25 T.C. 584, and Estate of Edward Carnall, 25 T.C. 654, where taxable transfers under Federal estate tax law were made by holders of entirety estates and it was held each transferred one-half. And there are instances of deviation from the pure fiction of the existence of one entity of entirety estates under the Missouri decisions.