Union Trust Co. of San Francisco v. Wardell

RUDKIN, District Judge.

Section 201 of the Act of September 8, 1916, 39 Stat. 777 (Comp. St. § 6336%b), imposes a tax upon the transfer of the net estate of every decedent dying after the passage of the act, whether a resident or nonresident of the United States. Section 202 (section 6336%c) provides:

“That the value of the gross estate of the decedent shall be determined by including the value at the time of his death of all property, real or personal, tangible or intangible, wherever situated: * * *

“(b) To the extent of any interest therein of which the decedent has at any time made a…