Kenan v. Commissioner of Internal Revenue

AUGUSTUS N. HAND, Circuit Judge.

The testatrix, Mrs. Bingham, died on July 27, 1917, leaving a will under which she placed her residuary estate in trust and provided in item “Seventh” that her trustees should pay a certain amount annually to her niece, Louise Clisby Wise, until the latter reached the age of forty, “at which time or as soon thereafter as compatible with the interests of my estate they shall pay to her the sum of Five Million ($5,000,000.00) Dollars.” The will provided in item “Eleventh” that the trustees, in the case of certain payments including that of the $5,000,000 under…