Humes v. United States (276 U.S. 487)

Under Revenue Act 1918, § 403, par.(a), subpar. 3 (Comp. St. § 6336 3/4 d), present value of contingent bequests to charities in will, as determined by combination and adjustment of mortality tables as to whether 15 year old girl would marry, or, if she did, would die without issue before age of 30, 35, or 40, is not deductible from gross amount in determining value of net estate in computing estate tax, since neither taxpayer nor revenue officer could do more than guess at value of contingency.

Mr. A. Lowry Humes, of New York City, for petitioners.

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Mr. W. D. Mitchell, Sol. Gen., of Washington, D. C., for the United states.

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Mr. Justice BRANDEIS delivered the opinion of the Court.