Sellers's Estate

Opinion by

Mr. Justice Stern,

This appeal is from imposition of a collateral inheritance tax upon certain real and personal property conveyed by Sarah P. Sellers to appellants in 1930 in trust to pay the net income therefrom to donor during her lifetime, and at her death to retain the principal for the creation, equipment and maintenance of a free, public library as a memorial to her parents. The deed of trust stipulated that the library should be under the management of a board of twelve, six of the original appointees being named in the deed, the others to be selected by the trustees. The…