Estate of Round v. Commissioner

OPINION

Opper, Judge:

Petitioner states the issues in its opening brief as follows:

1. Were the three trusts established in contemplation of death and thus taxable under Sec. 2035 of the Internal Revenue Code of 1954?

2. In respect of the three trusts, did the decedent at date of death possess the right, either alone or in conjunction with any person, to designate the persons who shall possess or enjoy the property or the income therefrom and thus make the corpora of the trust taxable under Sec. 2036(a) (2) of the Internal Revenue Code of 1954?

3. In respect of the three trusts was the enjoyment…