Blasdel v. Commissioner
United States Tax Court
Petitioners owned 289.26 acres of land which they thought could be profitably subdivided and sold in small tracts. In 1967, they created a trust, naming themselves as beneficiaries, and transferred the land to the trust.
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Petitioners owned 289.26 acres of land which they thought could be profitably subdivided and sold in small tracts. In 1967, they created a trust, naming themselves as beneficiaries, and transferred the land to the trust. Petitioners, as beneficiaries, then executed gift agreements transferring fractional shares of their beneficial interests in the trust to 18 family members (their children, the children's spouses, and petitioners' grandchildren). The trust instrument authorized the trustee to distribute periodically income and corpus, provided (1) the beneficiaries unanimously agreed to the…
1Opinion of the Court
Featherston, Judge:
Respondent determined identical deficiencies of $5,959.50 in the gift tax liabilities of Jacob W. Blasdel and Ruth Alice Blasdel for the calendar year 1967. The issue presented for decision is whether gifts of fractional beneficial interests in a trust made by petitioners to 18 family members (their children, the children’s spouses, and petitioners’ grandchildren) were gifts of present rather than future interest in property so as to entitle each petitioner to an exclusion from taxable gifts of $3,000 for each donee.
BINDINGS OF FACT
Jacob W. Blasdel and Ruth Alice Blasdel…
2Cases cited15 opinions
- United States v. PelzerSupreme Court of the United States · 1941
- Fondren v. CommissionerSupreme Court of the United States · 1945
- Commissioner v. DisstonSupreme Court of the United States · 1945
- Helvering v. HutchingsSupreme Court of the United States · 1941
- Ryerson v. United StatesSupreme Court of the United States · 1941
10 more not listed; retrieve them via the Exa API.
3Cited by14 opinions
- Berzon v. CommissionerUnited States Tax Court · 1975
- Calder v. CommissionerUnited States Tax Court · 1985
- Jacob W. Blasdel and Ruth Alice Blasdel v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1973
- Robert E. Hamilton and Mary v. Hamilton v. United StatesCourt of Appeals for the Ninth Circuit · 1977
- Hackl v. Comm'rUnited States Tax Court · 2002
9 more not listed; retrieve them via the Exa API.