National City Bank of New York v. Commissioner

OPINION.

Black, Judge:

The question which we have to decide in these proceedings is stated by petitioners in their brief as follows: Whether the values of three irrevocable trusts created by Charles F. Loudon during his lifetime are includible in his gross estate for Federal estate tax purposes under the provisions of section 811 (c) of the Internal Eev-enue Code, printed in the margin.1

The petitioners contend that the trusts in question were not intended by the decedent “to take effect in possession or enjoyment at or after his death” within the meaning of section 811 (c). They support this…