Quigley v. Commissioner of Internal Revenue

EVANS, Circuit Judge.

The facts: The parties stipulated that petitioner’s father died in 1917, leaving an estate of approximately two million dollars. She, her mother, and two brothers survived. Had the father died intestate, her share would have been approximately $400,-000. He left a will, however, wherein he created several trusts, spendthrift in nature.

The trust to petitioner was smaller than those which were made for her brothers.

Dissatisfied with the provision she thus received under the will, petitioner threatened to contest the will. Her threat was withdrawn, however, when she and her…