Estate of Hunnewell v. Commissioner

OPINION.

Aenold, Judge:

Respondent contends that the value of the transferred property which at decedent’s death was still subject to the possibility of reverting to decedent’s estate is includible in gross estate under section 811 (c) of the Internal Revenue Code,1 on the theory that the transfer was intended to take effect in possession or enjoyment at or after death. Petitioners claim that there was no such intent accompanying the transfer; that decedent’s death could have had no effect whatsoever on the interests of the beneficiaries; and that no part of the transferred property is…