Order of the Appellate Division reversed upon the authority of Matter of Zborowski (213 N. Y. 109), with costs in the Appellate Division and in this court payable from the estate. The proceeding is remitted to the Surrogate’s Court of New York county with direction to modify the order fixing the tax by deducting from the *715 value of the estate the value of the life estate of William J. Wright to which it was subject, and fixing the tax upon its remaining value; no opinion.

Concur: Werner, Hiscock, Chase, Collin, Hogan, Miller and Cardozo, JJ.