Legal Opinion

Cox v. Commissioner

United States Board of Tax Appeals

Decided October 13, 1938No. Docket No. 89292Published

1. Petitioner transferred $100,000 to a trust, the income to be paid to his son for life, portions of the corpus to be paid to the son when he attained certain ages and the remainder to be paid to transferor's wife or others.

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1. Petitioner transferred $100,000 to a trust, the income to be paid to his son for life, portions of the corpus to be paid to the son when he attained certain ages and the remainder to be paid to transferor's wife or others. Held, that the transfer was not of a future interest in property and petitioner, in computing his gift tax, properly excluded $5,000 from the amount transferred under section 504(b), Revenue Act of 1932. Commissioner v. Wells, 88 Fed.(2d) 339. 2. During the taxable period referred to in the preceding paragraph, petitioner transferred another $100,000 to his wife in trust…

1Opinion of the Court

EDWIN B. COX, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Cox v. Commissioner

Docket No. 89292.

United States Board of Tax Appeals

38 B.T.A. 865; 1938 BTA LEXIS 816;

October 13, 1938, Promulgated

1. Petitioner transferred $100,000 to a trust, the income to be paid to his son for life, portions of the corpus to be paid to the son when he attained certain ages and the remainder to be paid to transferor's wife or others. Held, that the transfer was not of a future interest in property and petitioner, in computing his gift tax, properly excluded $5,000 from the amount transferred under…

2Cases cited1 opinion

  1. Cox v. CommissionerUnited States Board of Tax Appeals · 1938

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