Estate of Anna R. Johnson

DOYLE, Justice.

The decedent, Anna R. Johnson, died testate on January 9, 1971. In her will, after making several small bequests, she left the bulk of her estate to Marjorie L. Kulbel, an unrelated friend. The will was contested by certain heirs at law of the decedent with the result that a compromise agreement was reached whereby the estate was divided 50% to Marjorie L. Kulbel and 50% in equal shares to the nine contesting heirs at law. The South Dakota Department of Revenue contends, and its contention was sustained in the lower court, that the inheritance tax due the state be computed on…