Hays' Estate v. Commissioner of Internal Revenue

HOLMES, Circuit Judge.

This petition for review involves a deficiency assessment of estates taxes against petitioner. The deficiency 1 resulted solely from the inclusion by the Commissioner in the decedent’s gross estate of the value of farm land in Mississippi, which-was transferred -by decedent to herself as trustee for the benefit of her four children and the heirs at law of any of said children who died during the continuance of the trust. The Tax Court sustained the Commissioner’s determination, because it held (1) that the trust instrument required the, mortgage debt on the land to be…