Maryland National Bank v. United States

THOMSEN, Chief Judge.

This is a suit by the executors under the will of Virginia Appleton Wilson to recover $28,671.85, together with $4,667.-62 statutory interest thereon, an aggregate of $33,339.46, paid by them as additional estate taxes following an assessment by the Internal Revenue Service. 1 The question presented is whether her executors should have included in her taxable estate the value of the corpus of a trust created by the will of her father, J. Appleton Wilson, under which she had a power of appointment.

J. Appleton Wilson executed his last will and testament in April 1926 and…