13 DECEMBER 1935, Page 7

The dismissal by the Supreme Court of the United States

of the claim of the United States Government for some 10,000,000 dollars death duties on the estate of the first Viscount Astor is of interest in itself, quite 'apart from its financial importance to the present Lord Astor and his brother, the chief proprietor of The Times. In this country gifts made within three. years before death are regarded as made " iii anticipation of death," and full death duties are levied on them. In the United States the period of two years and the ." anticipation of death " motive is treated only as a presumption, which can be rebutted by evidence 'that some other reason dictated the gift. In the present case the late Lord Astor put his estate in the hands of trustees shortly before his death, and they have sought- to prove that the fear of a capital levy on individuals was constantly in his mind, for which. reason he decided to put his property in trust. The files of papers, American and British, which he was known to read regularly were searched diligently for articles on such a levy and a large number were produced. That seems to have decided the issue.