Cory

*905 Opinion

Ernest Corda, as executor of the estate of William F. Corda, deceased, appeals after the court below entered an order overruling objections to the report of the inheritance tax referee and fixing the total inheritance tax due.

The referee’s report resulted in an order there is inheritance tax due on the value of assets William F. Corda gave to his children and their spouses more than seven years before his death on October 23, 1972.

In 1965, William F. Corda, then 74 years of age, made certain agreements among his family members under which he agreed to bargain, sell, convey, and transfer real and personal property, 2 including cash, securities and farm equipment totaling $267,326.80 to his three children and their respective spouses (Transferees). The transfers were *906 made partly as gifts and partly in exchange for promises by the Transferees to pay Mr. Corda a private annuity. From the promised annuities Mr. Corda was to receive a total of $14,000 per year for his life. No collateral or securities were given for the faithful performance of the annuity promises.

Each Transferee signed a document entitled “Agreement of Private Annuity,” reciting, among other…