Canfield v. Commissioner
United States Tax Court
1. By trust agreement executed in 1919, decedent transferred securities in trust to herself and a bank, as trustees, reserving to herself the income therefrom for life and the right to appoint by will the distribution of the trust estate after her death. The trust agreement also provided how and to whom the trust estate should be distributed on her death if decedent failed to exercise her testamentary power of appointment.
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1. By trust agreement executed in 1919, decedent transferred securities in trust to herself and a bank, as trustees, reserving to herself the income therefrom for life and the right to appoint by will the distribution of the trust estate after her death. The trust agreement also provided how and to whom the trust estate should be distributed on her death if decedent failed to exercise her testamentary power of appointment. Decedent reserved no right to revoke, alter, or amend the trust agreement and it was irrevocable under the laws of New York. By written instrument dated December 15, 1942,…
1Opinion of the Court
Estate of Ellie G. Canfield, Deceased, Karl B. Smith, Jr., Administrator, c.t.a., Petitioner, v. Commissioner of Internal Revenue, Respondent
Canfield v. Commissioner
Docket Nos. 69587, 69588
United States Tax Court
34 T.C. 978; 1960 U.S. Tax Ct. LEXIS 79;
September 15, 1960, Filed
Decision will be entered for the petitioner.
1. By trust agreement executed in 1919, decedent transferred securities in trust to herself and a bank, as trustees, reserving to herself the income therefrom for life and the right to appoint by will the distribution of the trust estate after her death. The trust agreement…
2Cases cited22 opinions
- Estate of Sanford v. CommissionerSupreme Court of the United States · 1939
- May v. HeinerSupreme Court of the United States · 1930
- Commissioner v. Estate of ChurchSupreme Court of the United States · 1949
- Helvering v. WoodSupreme Court of the United States · 1940
- Lehman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1940
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