Estate of Wolf v. Commissioner

OPINION.

Ratjm, Judge:

1. We hold that the Commissioner correctly included in the decedent’s gross estate the present value as of the date of death of the amounts payable under the profit-sharing trust and the two pension trust agreements. This result is required either by subsection (a) or subsection (f) of section 811, I. R. C. 1939.2 At the date of decedent’s death he had enforceable vested rights in the three trusts, procured by the rendition of services and by continuing in the employ of the respective corporations. He could be deprived of those rights only by deliberately terminating his…