HUTCHESON, Circuit Judge.
Appellant brought this suit to recover, as overpaid, estate taxes of $107,257.06 it had paid on a deficiency assessment based on the inclusion of the trust property in decedent's gross estate.
The primary claim of the suit was that the transfer in trust was not, within the meaning of Sec. 302(c), Rev.Act of 1926, 26 U.S.C.A.Int.Rev.Code, § 811(c), "intended to take effect in possession or enjoyment at or after [the] death [of...
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