This is an appeal from an order of the Tax Court finding a deficiency in the estate tax of the Estate of Sumner Gerard. That portion of the deficiency in issue on this appeal (approximately $482,000) is based on the determination that the decedent, Sumner Gerard, gave certain property as a gift in contemplation of death within the meaning of Section 2035 of the Internal Revenue Code of 1954. We affirm on the opinion of Judge Quealy of the Tax Court reported at 57 T.C. 749 (1972).