Pardee v. Commissioner

WOOLLEY, Circuit Judge.

_ , . Cal™ a f Pemsylvama| dled By his will he bequeathed aad devised certain property to his wife ab-?0 then £ave her 311 ammty of $50,000,” but by a later paragraph m the tJresidue 0f hislstate to trastees ^ £rug£ copecf; income and pay his wife the annuity wHch thereinbefore he had given her. Other provisions of the will indicate the annuity was for life, with remainders over as to the corpus.

The testator’s wife elected to take under the will in lieu of the interest in her husband’s estate which the law of Pennsylvania gave her.

During 1924 and 1925, the tax years in…