Manautou v. Noguera

There are two main questions involved in this proceeding : is the commuted value of the annuity policy subject to taxation under the provisions of Act No. 303 of April 12, 1946, 13 L.P.R.A. § 881 et seq., known as the Inheritance Tax? Is the amount of attorney’s fees paid by a trustee for the dissolution of a trust constituted by the deceased and whose corpus was distributed among certain persons at the death of said constituent deductible for the purposes of the liquidation of said tax?

I

At the sunset of his life—he was then about 70 years of age—José Manautou Fantauzzi acquired four annuity…