Legg's Estate v. Commissioner of Internal Revenue

PARKER, Circuit Judge.

This is a petition to review a decision of the Board of Tax Appeals, assessing deficiency estate taxes in the sum of $33,-027.20 with respect to property held to have passed under a general power of appointment, exercised by the will of one Mildred Sheppard Legg. Three contentions are made by petitioner: (1) that the power of appointment was not general but special; (2) that its exercise by the donee, with respect to a remainder interest covered, was void as contravening the rule against perpetuities;. and (3) that, with respect to the life estate taken by the daughter…