Commissioner v. Estate of Field

This is a companion case to Fidelity-Philadelphia Trust Co. v. Rothensies, ante, p. 108. It too presents a question as to the proper valuation of the corpus of an inter vivos trust under § 302 (c) of the Revenue Act of 1926, 44 Stat. 9, 70.

On June 8, 1922, the decedent transferred to a trustee certain assets valued at the date of his death at the sum of $157,452.82. The material portions of the trust provided:

1. The trust was to continue for the joint lives of two nieces and the life of the survivor of them unless terminated earlier under 4, infra.

2. The income was to be paid to the decedent…