First Victoria National Bank, Independent Under the Will of T. J. Babb, Deceased v. United States

GOLDBERG, Circuit Judge:

This case presents a question of first impression: whether “rice history acreage” interests under the system of rice allotments established by sections 351 to 356 of the Agricultural Adjustment Act of 1938, 52 Stat. 31 (codified as 7 U.S.C.A. §§ 1351-1356 (West 1973)) (“the Act”) constitute “property” includable in a decedent’s gross estate under sections 2031 and 2033 of the Internal Revenue Code of 1954. 1 Because an understanding of the rice allotment system is necessary to a full understanding of the facts of this case, we will first discuss the rice allotment…