In Re Estate of Hart

This is an appeal by the state Tax Commissioner from an order of the Probate Court of Franklin County determining inheritance taxes. Chapter 5731, Revised Code. The appeal is confined to the basis of taxation on one item only.

During his life the decedent borrowed $5,000 from Blanche Porter. He executed his promissory note, payable on demand, and delivered it to her. The note was unpaid at the time of his death. The will provided that she have a life estate in certain real property. It also established a trust of $12,000, and directed that Blanche Porter was to receive from income and…