Hodgkins v. Commissioner of Internal Revenue

EVANS, Circuit Judge.

Petitioners, through this appeal, seek to review the order of the Board of Tax Appeals which included as part of the estate of Jefferson Hodgkins, for taxation purposes, nine hundred shares of the stock of the Brownell Improvement Company of the fair market value of $260 per share. Hodgkins transferred this stock in trust about fourteen months prior to his death, which was January 2, 1921.

Three questions are presented: (a) the construction of the repeal section of the Revenue Act of 1921 (Estate Tax); (b) did Hodgkins execute the trust in contemplation of death? (e) the…