Estate of Beachy v. Commissioner

OPINION.

Hill, Judge:

The respondent urges that the value of the property of the Cyrus M. Beachy Trust No. 1 is includible in the decedent’s gross estate under any one of three theories: (1) that it represented property in which decedent had an interest under section 811 (a) of the Internal Revenue Code; (2) that the transfer on November 11, 1939, and subsequent transfers to the trust in question were in contemplation of death, or to take effect at death under section 811 (c); or (3) that the transfers were revocable within the purview of section 811 (d) (1).

The value of the property is not…