Estate of De Roulet

OPINION (1) The sole question on this appeal by the Controller from an order fixing the inheritance tax in the above estate is whether on the date of decedent's death, November 12, 1964, Vincent de Roulet, a mutually recognized grandchild of decedent, was under the Inheritance Tax Law properly classified as a Class A (close relative) or a Class D (stranger) transferee of decedent, Marie Louise de Roulet. The trial court found that Vincent was a person adopted as a minor by Henry de Roulet, his stepfather and the only child of decedent, and therefore concluded that Vincent was a Class A transferee of decedent under Revenue and Taxation Code section 13307, subdivision (e) of the law. 1 Subdivision (e) in 1964 read as follows: "A transferee whose relationship *Page 1074 to the decedent is that of a person adopted in conformity with the laws of this State by any lineal issue or child mentioned in this section; provided, such person was under the age of 21 years at the time of such adoption." The trial court further found that Henry and Vincent had the mutually acknowledged relationship of parent and child for more than 10 years prior to November 12, 1964, and that the relationship…