Kniep v. Commissioner
United States Tax Court
In determining the exclusions allowable under section 1003 (b) (3), Internal Revenue Code, in the case of gifts of present interests, the value of beneficiaries' interests in trust income for a term of years must be computed by deducting from corpus each year the amounts thereof which the trustees are authorized, conditionally, to distribute to the beneficiaries.
1Opinion of the Court
OPINION.
LeMiRe, Judge:
This proceeding involves gift tax deficiencies of $981.86 for 1943 and $1,113.60 for 1944. All of the facts are stipulated and we ado'pt the stipulation as our findings of fact herein.
The petitioner is a resident of University City, Missouri. The returns for the taxable years here involved were filed with the collector of internal revenue for the first district of Missouri, at St. Louis.
The petitioner created a trust on March 12, 1943, for the benefit of five of his nephews and nieces and a relative of his deceased wife. The income was to be paid to the beneficiaries…
2Cases cited4 opinions
- Merchants Nat. Bank of Boston v. CommissionerSupreme Court of the United States · 1943
- Geller v. CommissionerUnited States Tax Court · 1947
- Riter v. CommissionerUnited States Tax Court · 1944
- Holmes v. CommissionerUnited States Tax Court · 1945
3Cited by25 opinions
- Brody v. CommissionerUnited States Tax Court · 1952
- Evans v. CommissionerUnited States Tax Court · 1951
- Calder v. CommissionerUnited States Tax Court · 1985
- Jones v. CommissionerUnited States Tax Court · 1957
- Newlin v. CommissionerUnited States Tax Court · 1958
20 more not listed; retrieve them via the Exa API.