The following excerpt is from Estate of Maxwell v. C.I.R., 3 F.3d 591 (2nd Cir. 1993):
26 U.S.C. Sec. 2036(a). In the case of real property, the terms "possession" and "enjoyment" have been interpreted to mean "the lifetime use of the property." United States v. Byrum, 408 U.S. 125, 147, 92 S.Ct. 2382, 2395, 33 L.Ed.2d 238 (1972).
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