First Virginia Bank (A Corporation), Administrator of the Estate of Mary E. Helms v. United States

BUTZNER,' Circuit Judge:

The First Virginia Bank, administrator c. t. a. of the estate of Mary E. Helms, appeals from a judgment of the district court denying a refund of estate taxes. The district court ruled that Mrs. Helms’ gross estate included prop-, erty valued at approximately $88,000 because she held a general power of appointment with respect to it. A sense of unfairness casts a shadow over this case, and others of its kind, 1 because Mrs. Helms never exercised the power, and a change in its phrasing might well have accomplished its purpose without subjecting her estate to additional…