In re the Estate of Strong

John M. Keane, S.

“A frequent and troublesome source of litigation in recent years has been the recurrent problem of whether the use in a will or deed of a class designation such as ‘ children, ’ ‘ heirs, ’ ‘ descendants ’ or 6 issue ’ includes adopted children.” So begins Report No. 1.3B in the Second Report of the Temporary State Commission on the Modernization, Revision and Simplification of the Law of Estates (N. Y. Legis. Doc., 1963, No. 19, pp. 163-177,164). Upon recommendation of the commission, the Legislature has enacted chapter 310 of the Laws of 1963, creating section 49 of the…