In re the Estate of Bowers

Foley, S.

There are two appeals from the order assessing the transfer tax in this proceeding, one by the executors and trustees under the will of the decedent, the other by the trustees under deeds of trust and under an ante-nuptial agreement made by decedent, on the ground that the property transferred by certain of the instruments, was not subject to the ordinary transfer tax, and on the further ground that the securities forming part of the property transferred, were not liable to the tax provided for by section 221b of the Tax Law.

The decedent, in the deeds of trust, transferring the…