Estate of Vose v. Commissioner

OPINION.

HaReon, Judge:

The petitioners concede that the net value of the corpus of the Vose Family Trust at the time of decedent’s death is includible in his gross estate under the provisions of section 811 (c), Internal Revenue Code,2 because of the reservation by him in the trust instrument of the income of the trust for life. They contend, however, that the net value of the trust estate to be included in the gross estate is the fair market value of the trust corpus less the amount of legal encumbrances against it as of the date of decedent’s death; that the so-called “certificates of…