Estate of Snyder

This appeal is taken by John Whiteley Snyder, a son of the decedent Jennie W. Snyder, from an order of the superior court of San Diego County, imposing upon him an inheritance tax of $7,500 because of a conveyance made to him by his mother, prior to her death, of certain real property, here briefly designated as the Snyder Block. The same order fixed a tax of $17,377.78 to be paid by him on other properties to which he has succeeded under her will. The correctness of this portion of the order is undisputed. The contest in the court below and the object of this appeal is to determine whether or not the conveyance inter vivos of the mother to the son falls within the provisions of the Inheritance Tax Act. It is the contention of the grantee that it does not, for the reason that it was not made in contemplation of death. That it took effect in possession and enjoyment before the death of the grantor is not disputed.

The court found, however, that the conveyance was made in contemplation of death and without adequate or valuable consideration. The contention on which this appeal is based is that such finding is entirely unsupported by the evidence.

The deed of conveyance in question…