Remmel Estate

Concurring Opinion by

Mr. Justice Cohen :

Our problem here is to determine the impact of Article III “Transfers Not Subject to Tax” and decide *332whether that article gives us any clue or guide as to whether there shall be included in the “whole estate,” “gross estate,” “taxable estate,” “gross probate estate,” or whatever it might be called, the value of the property transferred to a charity. A superficial reading of Article III indicates that with the exception of governmental and charitable transfers, none of the “transfers not subject to tax” is includible in the gross estate.

Better…