Colorado National Bank v. Commissioner

The purpose of Congress in providing that property transferred to a trust should be included in the trans-feror’s gross estate when transferred in contemplation of death1 was to prevent evasion of the progressively grad*28uated estate tax through the use of trust devices which actually operated as substitutes for testamentary disposition of property.2 The will made by Mr. Hendrie at the age of seventy-eight in 1925 and the trust agreement substituted for it at eighty (as to a large part of his property) two years later in 1927 were substantially identical as to parties, recipients of his…