Frazer v. Commissioner
United States Tax Court
The will of Robert S. Frazer, father of decedent, created two trusts, terminating upon the death of the life beneficiaries. The trust remainders were to fall into the testator's residuary estate. Decedent was one of three residuary legatees under said will. Held, the value of a one-third interest in the trust remainders was taxable as part of the decedent's gross estate under section 811 (a), I. R. C.
1Opinion of the Court
OPINION.
Leech, Judge-.
This proceeding involves a deficiency in Federal estate tax in the amount of $29,286.15. The issue is whether the interest of the decedent in two trusts created by the will of decedent’s father are includible in decedent’s gross estate.
The facts have been stipulated and are found as stipulated.
John G. Frazer, the decedent, died testate on April 17, 1942, a resident of Pittsburgh, Pennsylvania. Katharine Reed Frazer is his widow and one of the duly qualified executors of said decedent’s estate. She, as executrix, filed a Federal estate tax return with the collector of…
2Cases cited4 opinions
- In Re the Judicial Settlement of the Accounts of JamesNew York Court of Appeals · 1895
- Allen v. HirlingerSupreme Court of Pennsylvania · 1907
- Raleigh's EstateSupreme Court of Pennsylvania · 1903
- Scott's EstateSupreme Court of Pennsylvania · 1933
3Cited by4 opinions
- Estate of Williams v. CommissionerUnited States Tax Court · 1974
- Frazer's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1947
- Estate of Williams v. CommissionerUnited States Tax Court · 1974
- Frazer v. CommissionerUnited States Tax Court · 1946