Inheritance Tax on Employe Salary Agreements

Vincent X. Yakowicz, Deputy Attorney General,

You have requested our opinion with respect to the taxability of the commuted value of monthly payments to be made to the decedent’s widow *83in conformity with a Salary Agreement executed by and between James W. Foxall, decedent, and Mushroom Transportation Company, Inc.

The decedent died on August 8, 1962, while the contract was in full force and effect.

Pertinent provisions of the agreement are as follows:

1. The term of the agreement is for a period of 12 years, commencing on January 1, 1955.

2. During the term of the agreement, the company will pay…