Thorp v. Commissioner
United States Tax Court
Where a trust created in 1918 by the decedent contained a power in decedent to terminate the trust, cutting off the remainder interest, upon the request of the life beneficiaries, held: (1) The value of the remainder interests transferred were includible in decedent's gross estate under section 811 (d) (2), I. R. C. (2) The application of said section does not infringe the due process clause of the Fifth Amendment.
1Opinion of the Court
Estate of Charles M. Thorp, Deceased, Goldie D. Thorp and Fidelity Trust Company, Executors, Petitioners, v. Commissioner of Internal Revenue, Respondent
Thorp v. Commissioner
Docket No. 7244
United States Tax Court
7 T.C. 921; 1946 U.S. Tax Ct. LEXIS 66;
October 7, 1946, Promulgated
Decision will be entered under Rule 50.
Where a trust created in 1918 by the decedent contained a power in decedent to terminate the trust, cutting off the remainder interest, upon the request of the life beneficiaries, held:(1) The value of the remainder interests transferred were includible in decedent's gross estate…
2Cases cited11 opinions
- Estate of Sanford v. CommissionerSupreme Court of the United States · 1939
- Porter v. CommissionerSupreme Court of the United States · 1933
- Reinecke v. SmithSupreme Court of the United States · 1933
- Commissioner v. Estate of HolmesSupreme Court of the United States · 1946
- Helvering v. HelmholzSupreme Court of the United States · 1935
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