Estate of Valentine v. Commissioner
United States Tax Court
Decedent, on June 6, 1932, made a transfer in trust, which provided, inter alia, that the trustees pay to her from the principal of the trust corpus $ 150,000 annually, and upon her death the remaining principal of the corpus was to be divided among designated heirs. The value of this reversionary interest immediately before her death in 1965 at the age of 95 exceeded 5 percent of the value of the property transferred to the trust.
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Decedent, on June 6, 1932, made a transfer in trust, which provided, inter alia, that the trustees pay to her from the principal of the trust corpus $ 150,000 annually, and upon her death the remaining principal of the corpus was to be divided among designated heirs. The value of this reversionary interest immediately before her death in 1965 at the age of 95 exceeded 5 percent of the value of the property transferred to the trust. In filing the estate tax return for decedent's estate, the executors in the computation of the gross estate included, on account of her right to annual invasions…
1Opinion of the Court
Estate of May L. Valentine, Deceased, Lester Armour and T. Stanton Armour, Formerly Co-executors, Petitioners v. Commissioner of Internal Revenue, Respondent; The May L. Valentine June 6, 1932 Trust, Lester Armour and Patrick A. Valentine, Co-trustees, Petitioner v. Commissioner of Internal Revenue, Respondent
Estate of Valentine v. Commissioner
Docket Nos. 3379, 3380-681
United States Tax Court
54 T.C. 200; 1970 U.S. Tax Ct. LEXIS 218;
February 9, 1970, Filed
Decisions will be entered under Rule 50.
Decedent, on June 6, 1932, made a transfer in trust, which provided, inter alia, that the trustees…
2Cases cited27 opinions
- Helvering v. HallockSupreme Court of the United States · 1940
- Fidelity-Philadelphia Trust Co. v. RothensiesSupreme Court of the United States · 1945
- Commissioner v. Estate of FieldSupreme Court of the United States · 1945
- Goldstone v. United StatesSupreme Court of the United States · 1945
- Liebmann v. HassettCourt of Appeals for the First Circuit · 1945
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