Ohio Code § 5731.07

§ 5731.07.

(A) The value of the gross estate shall include the value of all property, to the extent

of any interest therein of which the decedent has at any time made a transfer, except

in the case of a bona fide sale for an adequate and full consideration in money or

money's worth, by trust or otherwise, if both of the following conditions exist: (1) Possession or enjoyment of the property can, through ownership of such interest,

be obtained only by surviving the decedent;  and (2) The decedent has retained a reversionary interest by the express terms of the instrument

of transfer and the value of such reversionary interest immediately before the death

of the decedent exceeds five per cent of the value of such property. (B) “ Reversionary interest ” includes a possibility that property transferred by the decedent may return to him

or to his estate or become subject to a power of disposition by him and its value

shall be determined immediately before the death of the decedent by the usual methods

of valuation, including the use of tables of mortality and actuarial principles, under

rules and regulations prescribed by the tax commissioner.