Legal Opinion

Estate of Lenna v. Commissioner

United States Tax Court

Decided July 18, 1960No. Docket No. 65566Unpublished

Held, transfers of certain property made by the decedent, within three years of her death, in establishing separate and irrevocable trusts in favor of her three children were not made in contemplation of death and are not includible in her gross estate under section 2035(a) and (b), Internal Revenue Code of 1954.

1Opinion of the Court

Estate of Hilda M. Lenna, Deceased, Harry A. Lenna, Reginald A. Lenna and Helen L. Milham, Executors v. Commissioner.

Estate of Lenna v. Commissioner

Docket No. 65566.

United States Tax Court

T.C. Memo 1960-153; 1960 Tax Ct. Memo LEXIS 135; 19 T.C.M. (CCH) 803; T.C.M. (RIA) 60153;

July 18, 1960

Held, transfers of certain property made by the decedent, within three years of her death, in establishing separate and irrevocable trusts in favor of her three children were not made in contemplation of death and are not includible in her gross estate under section 2035(a) and (b), Internal Revenue Code of…

2Cases cited10 opinions

  1. United States v. WellsSupreme Court of the United States · 1931
  2. Allen v. Trust Co. of Ga.Supreme Court of the United States · 1946
  3. Commissioner of Internal Revenue v. Estate of Harry A. Ellis, Deceased, Helen R. Ellis, Bernard B. Largman and Dan Denenberg, ExecutorsCourt of Appeals for the Third Circuit · 1958
  4. Ellis v. CommissionerUnited States Tax Court · 1956
  5. Commercial Nat'l Bank v. CommissionerUnited States Board of Tax Appeals · 1937

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