United States v. Estate of Stephen P. Farish, Jr., Deceased, Anne Francis Farish, Independent

This appeal is from a district court determination that certain properties held in trust for the decedent, Stephen P. Farish, Jr.,.are not within his taxable estate. Convinced that this decision was correct, we affirm.

The material facts are not in dispute and may be simply stated. Stephen P. Farish, Jr. was the sole beneficiary of three trusts (Trusts 1, 2 and 3) established by his parents in the 1930’s. All three trusts provided for gifts over on certain contingencies; the gift over provisions of Trusts 2 and 3 are identical, but are different from that of Trust 1. Farish died at age 31…