Helvering v. City Bank Farmers Trust Co.

The Revenue Act of 1926, § 302 (d), 1 provides:

“The value of the gross estate of the decedent shall be determined by. including the value at the time of his death of all property, real or personal, tangible or intangible, wherever situated—

“(d) To the extent of any interest therein of which the decedent has at any time made a transfer, by trust or otherwise, where the enjoyment thereof was subject at the date of his death to any change through the exercise of a power, either by the decedent alone or in conjunction with any person, to alter, amend, or revoke, . . .”

The questions for decision…