In City Bank Farmers Trust Co. v. McGowan, 323 U.S. 594, 65 S.Ct. 496, 89 L.Ed. 483 (1945), the Supreme Court addressed the question whether gratuitous transfers of an incompetent's property by a court acting on her behalf constituted transfers by the "decedent" as described in section 302(e) of the Revenue Act of 1926. The Court held that where a court acts on behalf of an incompetent pursuant to statutory authority, an act by the court is in legal effect the act of the incompetent. City Bank, 323 U.S. at 598-99, 65 S.Ct. at 497-98. The Court commented that it would be "sticking in the bark" to consider transfers by the court differently than transfers by the incompetent merely because the applicable section of the Internal Revenue Code did not add a phrase specifically addressing transfers made for the benefit of the incompetent pursuant to statutory authorization. Id. at 599, 65 S.Ct. at 498.