Estate of Muscle v. Division of Taxation, 26 N.J. Tax 192 (N.J. Tax Ct. 2011)

(decedent's gift of shares of stock to lifelong friend within six months of death deemed to have been in contemplation of death based on all facts and circumstances; statutory presumption of N.J.S.A. Sec. 54:33-1 et seq. that such transfer is a taxable as a testamentary substitute if made within three years of death not overcome; value of gifted stock included in decedent's gross estate for state inheritance/estate tax purposes).