Estelle Want, Trustee and Transferee v. Commissioner of Internal Revenue

FRIENDLY, Circuit Judge.

Petitioner, Estelle Want, is the sister of Jacob A. Want, who was the founder of a corporation engaged in the printing business and its president until his death in February 1947. In January, 1945, Jacob Want established a trust for his only child, Jacqueline. He named pe titioner and a brother, Samuel, as co-trustees. Jacob transferred to the trust $82,000 in cash in 1945 and 397 of the 400 outstanding shares of the corporation in 1946. Petitioner and Samuel were also named as co-executors in Jacob’s will executed in April, 1945; the will bequeathed his entire estate…