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LLOYD'S ESTATE v. COMMISSIONER OF INTERNAL REVENUE

No. 8264.

141 F.2d 758 (1944)

LLOYD'S ESTATE et al. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Third Circuit.

Decided March 31, 1944.

Attorney(s) appearing for the Case

Henry S. Drinker, Jr., of Philadelphia, Pa. (Frederick E. S. Morrison and Calvin H. Rankin, both of Philadelphia, Pa., on the brief), for petitioners.

Muriel S. Paul, of Washington, D. C. (Samuel O. Clark, Jr., Asst. Atty. Gen., Sewall Key and J. Louis Monarch, Sp. Assts. to the Atty. Gen., on the brief), for respondent.

Before MARIS, JONES, and GOODRICH, Circuit Judges.

JONES, Circuit Judge.

H. G. Lloyd, the decedent, created a separate inter vivos trust for each of his two sons for life with certain respective trust powers and provisions as to the remainders. The question here involved is whether the settlor thereby transferred interests in property "intended to take effect in possession or enjoyment at or after his death" within the meaning of Sec. 302(c) of the Revenue Act of 1926.

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