Estate of Spiegel v. Commissioner

This is a federal estate tax controversy. Here, as in Commissioner v. Church, ante, p. 632, we granted cer-tiorari to consider questions dependent upon the meaning and application of a provision of § 811 (c) of the Internal Revenue Code. 47 Stat. 169, 279, as amended, 26 U. S. C. §811 (c). The particular provision requires including in a decedent’s gross estate the value at his death of all property “To the extent of any interest therein of which the decedent has at any time made a transfer, by trust or otherwise . . . intended to take effect in possession or enjoyment at or after his death

In…