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ESTATE OF BRADLEY v. COMMISSIONER

Docket No. 109069.

1 T.C. 518 (1943)

ESTATE OF EDWARD E. BRADLEY, DECEASED, THE WASHINGTON TRUST COMPANY, EXECUTOR, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated February 2, 1943.

Attorney(s) appearing for the Case

Charles Wells Gross, Esq., for the petitioner.

Davis Haskin, Esq., for the respondent.

OPINION.

ARUNDELL, Judge:

The Commissioner determined a deficiency of $63,244.44 in estate tax. Minor adjustments are not disputed. The issue is whether the value of the corpora of two irrevocable trusts created by decedent prior to 1931 should be included within his gross estate. This turns primarily upon whether the transfers were intended to take effect in possession or enjoyment at or after decedent's death...

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