In Re Brockett

Francis E. Brockett, a resident of this state, died testate in 1929, leaving no estate after payment of his debts and administration expenses. In 1924 he had made a deed of trust whereby he transferred to trustees property appraised by the comptroller at $221,534.21. Tax was assessed by the comptroller, under the statute (P.L. 1909 ch. 228, as amended), computed on the full value of this property, on the ground of a transfer intended to take effect in possession or enjoyment at or after the death of the transferor. From this tax the executors appeal.

Appellants admit that there was a transfer,…