Corbett v. Commissioner
United States Tax Court
1. The decedent created an inter vivos trust under which his then wife, the petitioner, was to receive trust income during his life, provided she remained his wife; and was to receive trust income for her lifetime, provided she was his wife at the time of his death. In the event she ceased to be his wife during his lifetime, he was to receive the trust income.
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1. The decedent created an inter vivos trust under which his then wife, the petitioner, was to receive trust income during his life, provided she remained his wife; and was to receive trust income for her lifetime, provided she was his wife at the time of his death. In the event she ceased to be his wife during his lifetime, he was to receive the trust income. Held, that the life estate of the petitioner in the trust was a contingent interest which was in suspense until the grantor's death and was, therefore, an interest which was intended to take effect in possession and enjoyment at or…
1Opinion of the Court
OPINION.
HaRROn, Judge:
Petitioner has agreed at all times that there should be included in the gross estate the value of the remainder interest in the trust which was created on December 8, 1927, because the decedent retained the power to change the beneficiaries and the amount of income to be paid to them, except with respect to the then Alice F. Corbett, and to modify the provisions of the trust.
The first question raised by the pleadings is whether the value of the life estate of Alice F. Corbett Mitchell is includible in the gross estate, as respondent has determined, under section 811 (c)…
2Cases cited10 opinions
- Helvering v. HallockSupreme Court of the United States · 1940
- Reinecke v. Northern Trust Co.Supreme Court of the United States · 1929
- May v. HeinerSupreme Court of the United States · 1930
- Commissioner v. Estate of ChurchSupreme Court of the United States · 1949
- Klein v. United StatesSupreme Court of the United States · 1931
5 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Estate of Christ v. Comm'rUnited States Tax Court · 1970
- Thacher v. CommissionerUnited States Tax Court · 1953
- Lockie v. CommissionerUnited States Tax Court · 1953
- Corbett v. CommissionerUnited States Tax Court · 1949
- Estate of Christ v. Comm'rUnited States Tax Court · 1970
2 more not listed; retrieve them via the Exa API.