Owen J. Roberts

“ The Act of 1924 altered existing law and authorized the deduction of claims against an estate only to the extent that they were 'incurred or contracted bona fide and for a fair consideration in money or money's worth.' [8] Congress had reason to think that the phrase 'fair consideration' would be held to comprehend an instance of a promise which was honest, reasonable, and free from suspicion whether or not the consideration for it was, strictly speaking, adequate. ”

“ The right to the deduction is qualified by the provision 'The amount of the deduction under this paragraph for any transfer shall not exceed the value of the transferred property required to be included in the gross estate.' The only transfers required to be included in the gross estate are those made in contemplation of death or to take effect in possession or enjoyment at or after death. ”

“ She paid the stipulated amount for one and one-half years prior to her death and the petitioner, as executor, paid for one year subsequent to her death. There were no available funds for the employment of a director except those received from the decedent and the Institute would not have employed one except for her agreement. It is an educational institution and does not operate for profit. ”