In Re Hill's Estate. Bodine v. Commissioner of Internal Revenue

SWAN, Chief Judge.

This appeal involves a deficiency in the federal estate tax assessed against the estate of Walter J. Hill, deceased. Section 811(a) of the Internal Revenue. Code, 26 U.S.C.A. § 811(a), requires that there be included in the gross estate of a decedent “the value at the time of his death of all property * * * to the extent of the interest therein of the decedent at the time of his death”. 1 On January 2, 1919, Mr. Hill had set up an irrevocable trust for the 'benefit of his wife, their infant daughter and the daughter’s issue, if any survived her. The trust was to terminate…