In re the Estate of Watson

Foley, S.

The appeal of the executors from the order fixing the transfer tax on the ground that property has been included which is not taxable in an estate of a non-resident decedent, is sustained. The property in dispute came to this decedent from his father’s estate. The decedent here died April 27, 1921; his father, William Watson, died in 1877. The latter’s wifi directed the conversion of his real estate into cash with an imperative power of sale. Under the doctrine of equitable conversion, the real property thereby became personal property for the purposes of the trust. Upon the death of…