In re the Estate of Barnaby

Fowler, S.

This appeal is taken by the executrix from the report of the appraiser and the order entered thereon on the ground that an exemption of $5,000 was not allowed in fixing a tax on the sum of $185,061.55, passing to Mary Lewis Kirkman, who was adopted by the testatrix 11 in conformity with the laws of this state. ’ ’ The decision of the question involved requires an interpretation of sections 221 and 221-a of the Tax Law. 'Section 221 provides, under the caption 1 ‘ Exceptions and Limitations, ’ ’ in part as follows: “ * * * There shall also be exempted from and not subject to the…