Court of Appeals for the Fifth Circuit March 20, 1941, 9721 (Commissioner of Internal Rev. v. Wilder's Estate)

SIBLEY, Circuit Judge.

A, M. Wilder died May 19, 1937, resident in Louisiana, survived by. his wife, Josephine.. In computing estate taxes the Commissioner included in the estate one-half of $104,356, which he determined to be the then value of four annuity contracts issued by New York Life Insurance Company. The Board of Tax Appeals, following its decision in Qise v. Commissioner, 41 B.T.A.