Pennsylvania Co. for Insurance on Lives & Granting of Annuities v. Helvering

GRONER, Associate Justice.

Tlio issue presented on this appeal is whether a bequest to the American Anti-Vivisection Society of Philadelphia is exempt from estate tax under the provisions of section 303 (a) (3) of the Revenue Act of 1024 (43 Stat. 253, 2,6 TJSCA § 1095 note). Petitioner is the executor of the estate of one A. Sydney Logan, deceased, who by last will bequeathed to the society a sum of money in excess of $200,000.

The applicable statute (section 303) provides: “For tlie purpose of the [estate] tax the value of the net estate shall be determined —(a) In the ease of a resident, by…