Legal Opinion
The Union Commerce Bank, Transferee v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided December 14, 1964No. 15607PublishedCited by 17 opinions
1Opinion of the Court
EDWARDS, Circuit Judge.
This appeal requires interpretation of Section 2036(a) of the Internal Revenue Code of 1954 — the pertinent portions of which are quoted below:
“Transfers with retained life estate
“(a) General rule. — The value pf the gross estate shall include the value of all property (except real property situated outside of the United States) to the extent of any interest therein of which the decedent has at any time made a transfer (except in ease of a bona fide sale for an adequate and full consideration in money or money’s worth), by trust or othesnvise, under which he has…
2Cases cited11 opinions
- United States v. StapfSupreme Court of the United States · 1964
- Goodwin's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1953
- Hornor's Estate v. COMMISSIONER OF INTERNAL REVENUECourt of Appeals for the Third Circuit · 1942
- Hornor v. CommissionerUnited States Board of Tax Appeals · 1941
- Mildred Sexton, of the Last Will of Bertha Birk Klein, Deceased v. United StatesCourt of Appeals for the Seventh Circuit · 1962
6 more not listed; retrieve them via the Exa API.
3Cited by17 opinions
- State v. ShueOhio Court of Appeals · 1994
- Todd v. CommissionerUnited States Tax Court · 1971
- T. S. Ballance, Administrator De Bonis Non With the Will Annexed of the Estate of Samuel D. Jarvis, Deceased v. United StatesCourt of Appeals for the Seventh Circuit · 1965
- Estate of Mary F. Colton Park, Detroit Bank and Trust Company, Administrator With Will Annexed v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1973
- Estate of Webster v. CommissionerUnited States Tax Court · 1976
12 more not listed; retrieve them via the Exa API.