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ESTATE OF GOODYEAR v. COMMISSIONER

Docket No. 171.

2 T.C. 885 (1943)

ESTATE OF ELLEN PORTIA CONGER GOODYEAR, ANSON C. GOODYEAR, CHARLES W. GOODYEAR, BRADLEY GOODYEAR AND ARNOLD B. WATSON, EXECUTORS, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated October 15, 1943.

Attorney(s) appearing for the Case

Thomas R. Wheeler, Esq., and John L. Kenefick, Esq., for the petitioners.

Harold D. Thomas, Esq., for the respondent.

OPINION.

ARUNDELL, Judge:

The Commissioner determined an estate tax deficiency in the amount of $431,676.03. The principal issue is whether respondent erred in determining that the remainder interests in four trusts created by decedent in her lifetime were intended to take effect in possession or enjoyment at or after her death within the meaning of section 811 (c) of the Internal Revenue Code. Also in issue is

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