Koshland's Estate v. Commissioner of Internal Revenue

HEALY, Circuit Judge.

• This case involves federal estate taxes. The question, affirmed by the taxpayer and denied by the Commissioner, is whether the Tax Court was in error in holding it proper to compute the remainder interest in a trust in conformity with existing treasury regulations.

In 1922 the decedent, Koshland, created a trust of securities in favor of his wife for the period of 'her life, the income to be paid her quarterly or oftener. In event the income in any year might prove less than $15,000, the trustees were authorized to resort to the principal. A son of the couple was…