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PENNSYLVANIA CO., ETC. v. UNITED STATES

No. 45889.

62 F.Supp. 697 (1945)

PENNSYLVANIA CO. FOR INSURANCES ON LIVES & GRANTING ANNUITIES et al. v. UNITED STATES.

Court of Claims.

October 1, 1945.

Attorney(s) appearing for the Case

Frank J. Albus, of Washington, D. C., for plaintiffs.

Elizabeth B. Davis, of Washington, D. C., and Samuel O. Clark, Jr., Asst. Atty. Gen. (Robert N. Anderson and Fred K. Dyar, both of Washington, D. C., on the brief), for defendant.

Before WHALEY, Chief Justice, and LITTLETON, WHITAKER, JONES, and MADDEN, Judges.

MADDEN, Judge.

The issue in this estate tax case is whether the Commissioner of Internal Revenue properly included in the gross estate of the decedent, Edward C. Knight, Jr., certain property transferred by him in trust June 28, 1912. The basis of the Commissioner's action was that under the trust instrument there was a possibility of reverter which could not terminate until decedent's death and therefore the transfer was intended to take effect at decedent's death...

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