Estate of Kolker v. Commissioner
United States Tax Court
In 1976, grantor created a trust to give her grandchildren $ 3,000 on June 13 of each year, beginning in 1977. The money was only to go to beneficiaries who were alive at the time the distributions were made. Held, the transfer to the trust was a gift of future interests to the beneficiaries; petitioner, therefore, is not entitled to claim 13 annual exclusions under sec. 2503(b), I.R.C. 1954.
1Opinion of the Court
Estate of Miriam R. Kolker, Deceased, Fabian H. Kolker and Gloria K. Hack, Personal Representatives, Petitioner v. Commissioner of Internal Revenue, Respondent
Estate of Kolker v. Commissioner
Docket No. 17058-80
United States Tax Court
80 T.C. 1082; 1983 U.S. Tax Ct. LEXIS 74; 80 T.C. No. 58;
May 25, 1983, Filed
Decision will be entered for the respondent.
In 1976, grantor created a trust to give her grandchildren $ 3,000 on June 13 of each year, beginning in 1977. The money was only to go to beneficiaries who were alive at the time the distributions were made. Held, the transfer to the trust was a…
2Cases cited12 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- 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
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