Commissioner of Internal Revenue v. Pennsylvania Co.

THOMPSON, Circuit Judge.

This is a petition for review of a decision of the Board of Tax Appeals. Under the terms of the will and codicil of Joseph G. Hendrickson, deceased, the respondent became the substituted executor and trustee of the decedent’s estate. Under the provisions of the will, the decedent gave a portion of his residuary estate to his executors in trust to pay the income to his sister, Addie C. Carpenter, for life, with remainders over after her death. Addie C. Carpenter died in 1930. The respondent paid the collateral inheritance taxes to the commonwealth of Pennsylvania upon…