Legal Opinion
Harris v. Commissioner
Supreme Court of the United States
Decided November 27, 1950No. 14PublishedCited by 151 opinions
1Opinion of the CourtJustice Douglas
The federal estate tax and the federal gift tax, as held in a line of cases ending with Commissioner v. Wemyss, 324 U. S. 303, and Merrill v. Fahs, 324 U. S. 308, are construed in pari materia, since the purpose of the gift tax is to complement the estate tax by preventing tax-free depletion of the transferor’s estate during his lifetime. Both the gift tax1 and the estate tax2 exclude transfers *108made for “an adequate and full consideration in money or money’s worth.” In the estate tax this requirement is limited to deductions for claims based upon “a promise or agreement”;3 but the…
2Cases cited7 opinions
- Commissioner v. WemyssSupreme Court of the United States · 1945
- Merrill v. FahsSupreme Court of the United States · 1945
- Mitchell v. OvermanSupreme Court of the United States · 1881
- Commissioner of Internal Revenue v. MaresiCourt of Appeals for the Second Circuit · 1946
- Harris v. Commissioner of Internal Revenue. Commissioner of Internal Revenue v. HarrisCourt of Appeals for the Second Circuit · 1949
2 more not listed; retrieve them via the Exa API.
3Cited by151 opinions
- Bob Jones University v. United StatesSupreme Court of the United States · 1983
- Richard Venable v. William H. Meyers, Defendant-AppelleantCourt of Appeals for the Ninth Circuit · 1974
- Padgett v. NicholsonCourt of Appeals for the Federal Circuit · 2007
- McMurtry v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1953
- Galt v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1954
146 more not listed; retrieve them via the Exa API.