In re the Estate of Jenney

Delehanty, S.

On September 30, 1947, an order was made fixing the estate tax on the basis of the appraiser’s report. From that order the State Tax Commission appeals on the ground that the appraiser erroneously excluded from the gross tax estate of deceased the value of certain rights of deceased derived from the terms of a deed to land in Texas. A second ground of appeal was specified but has now been abandoned and the only question presented has to do with the nature of the property right under the deed to Texas property.

Deceased’s rights stem from the will of her mother, Mary I. Jenney, who…