Clark v. Commissioner
United States Tax Court
Held, that deductions from gross estate on account of a revocable inter vivos trust for charitable purposes, should be reduced by the amount of Federal estate taxes and state inheritance taxes paid on such transfer. Section 301 (a) (3), Revenue Act of 1926, as amended, construed.
Read the full summary
Held, that deductions from gross estate on account of a revocable inter vivos trust for charitable purposes, should be reduced by the amount of Federal estate taxes and state inheritance taxes paid on such transfer. Section 301 (a) (3), Revenue Act of 1926, as amended, construed. Held, further, that trustees' commissions for distributing trust corpus, and attorneys' fees for services performed after decedent's death in connection with trustees' accounting, were charges against gross estate and properly deducted therefrom.
1Opinion of the Court
OPINION.
Disney, Judge:
This proceeding involves estate tax liability, a deficiency in which was determined in the amount of $17,514.64. All facts were stipulated, and we adopt as our findings of fact those set forth in such stipulation. The Federal estate tax return was filed with the collector at Denver, Colorado. The questions presented are as to whether the Commissioner erred in the reduction of deductions for charitable transfers, attorneys’ fees, and trustees’ commissions.
In summary, the facts involved are: That Charles W. Waterman died in 1932, leaving, in addition to property jointly…
2Cases cited5 opinions
- United States v. WellsSupreme Court of the United States · 1931
- Nichols v. CoolidgeSupreme Court of the United States · 1927
- Heiner v. DonnanSupreme Court of the United States · 1932
- Milliken v. United StatesSupreme Court of the United States · 1931
- Edwards v. SlocumSupreme Court of the United States · 1924
3Cited by10 opinions
- Burrow Trust v. CommissionerUnited States Tax Court · 1963
- Abbett v. CommissionerUnited States Tax Court · 1952
- Haggart's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1950
- Haggart v. CommissionerUnited States Tax Court · 1949
- Estate of De Foucaucourt v. CommissionerUnited States Tax Court · 1974
5 more not listed; retrieve them via the Exa API.