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CITY BANK CO. v. McGOWAN

No. 294.

323 U.S. 594 (1945)

CITY BANK FARMERS TRUST CO. (FORMERLY FARMERS LOAN & TRUST CO.), ADMINISTRATOR, v. McGOWAN, COLLECTOR OF INTERNAL REVENUE.

Supreme Court of United States.

Decided January 29, 1945.

Attorney(s) appearing for the Case

Messrs. James Lloyd Derby and J. Seymour Montgomery, Jr., with whom Messrs. Frederick P. King and John K. Watson were on the brief, for petitioner.

Assistant Attorney General Samuel O. Clark, Jr., with whom Solicitor General Fahy, Messrs. Sewall Key, J. Louis Monarch, Carlton Fox and Chester T. Lane were on the brief, for respondent.

MR. JUSTICE ROBERTS delivered the opinion of the Court.

This case presents an issue of importance arising under § 302 (c) of the Revenue Act of 1926, as amended,1 which requires inclusion, in the gross taxable estate of a decedent, of any interest in property of which the "decedent has at any time made a transfer . . . in contemplation of . . . his death . . ." More specifically, the inquiry is whether the section reaches allowances...

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