Bagnall v. Commissioner

HEALY, Circuit Judge.. This is a proceeding to review a decision of the Board qf Tax Appeals sustaining the assessment of a deficiency.

In 1928 Albert Lawrence Bagnall, a resident of California, established a trust inter vivos, vesting in the trustee title to certain- shares of corporate stock. The trust was irrevocable and was admittedly made in contemplation of death. It was created primarily for the benefit of the trustor’s wife, petitioner here, it b.eing provided that she is to receive during her- life the entire net income of the property. Bagnall died testate in September, 1929, leaving…