Cranston

This is an appeal by the surviving widow and executrix of the estate of Edward George Keeble, from an order fixing inheritance taxes. She concedes that the transfers to her of a life estate and special power of appointment by the will of her late husband are transfers subject to the inheritance tax, but contends that the amount of tax was erroneously computed and that the method of computation applied violated the equal protection clause of the state and federal Constitutions.

The appeal is on an agreed statement setting forth the following facts: Edward George Keeble died on July 15, 1962, leaving an estate consisting entirely of community property valued in excess of one million dollars. His will bequeathed certain personal effects to appellant and provided that all the rest of his portion of the community property was to be held in trust for appellant for life. Appellant received the unrestricted possession of the family home and outbuildings and the entire net income of the trust during her lifetime. At the discretion of the trustee, the corpus could also be used for the benefit of appellant. The only child of appellant and the decedent was named as trustee, and together with…