Legal Opinion

Camp v. Commissioner

United States Tax Court

Decided October 6, 1950No. Docket No. 13964Published

1. Gift Tax -- Transfer in Trust. -- Where a transfer in trust in 1932 was made with a reserved power in the grantor to revoke in whole or in part in conjunction with a contingent remainderman who agreed to comply with grantor's wishes as to subsequent changes, held not a completed gift of the entire trust property. 2. Where by amendment on December 11, 1937, the grantor's wife, who as the present income beneficiary had a substantial adverse interest, was substituted as the…

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1. Gift Tax -- Transfer in Trust. -- Where a transfer in trust in 1932 was made with a reserved power in the grantor to revoke in whole or in part in conjunction with a contingent remainderman who agreed to comply with grantor's wishes as to subsequent changes, held not a completed gift of the entire trust property. 2. Where by amendment on December 11, 1937, the grantor's wife, who as the present income beneficiary had a substantial adverse interest, was substituted as the only person in conjunction with whom petitioner could thereafter revoke the trust, held, a completed gift of the entire…

1Opinion of the Court

Frederic E. Camp, Petitioner, v. Commissioner of Internal Revenue, Respondent

Camp v. Commissioner

Docket No. 13964

United States Tax Court

15 T.C. 412; 1950 U.S. Tax Ct. LEXIS 71;

October 6, 1950, Promulgated

Decision will be entered under Rule 50.

1. Gift Tax -- Transfer in Trust. -- Where a transfer in trust in 1932 was made with a reserved power in the grantor to revoke in whole or in part in conjunction with a contingent remainderman who agreed to comply with grantor's wishes as to subsequent changes, held not a completed gift of the entire trust property.

2. Where by amendment on December 11,…

2Cases cited7 opinions

  1. Helvering v. CliffordSupreme Court of the United States · 1940
  2. Estate of Sanford v. CommissionerSupreme Court of the United States · 1939
  3. Burnet v. GuggenheimSupreme Court of the United States · 1933
  4. Smith v. ShaughnessySupreme Court of the United States · 1943
  5. Gillette v. CommissionerUnited States Tax Court · 1946

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