Legal Opinion
Burr v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided July 17, 1946No. 133, Docket 19992PublishedCited by 20 opinions
1Opinion of the Court
CLARK, Circuit Judge.
This is a petition by executors of a decedent’s estate for review of a decision of the Tax Court, holding taxable under § 811(c) of the Internal Revenue Code, 26 U.S.C.A. Int.Rev.Code, § 811(c), three life insurance policies which the decedent took out in connection with an annuity and thereafter assigned irrevocably to the beneficiaries. The only real issue concerns the effect of the assignment under the applicable statute which makes taxable transfers with reserved life interests.
The decedent’s purchase of the policies was in conformity with the typical annuity-life…
2Cases cited7 opinions
- Helvering v. Le GierseSupreme Court of the United States · 1941
- Goldstone v. United StatesSupreme Court of the United States · 1945
- Estate of Keller v. CommissionerSupreme Court of the United States · 1941
- Commissioner of Internal Revenue v. CliseCourt of Appeals for the Ninth Circuit · 1941
- Commissioner of Internal Rev. v. Wilder's EstateCourt of Appeals for the Fifth Circuit · 1941
2 more not listed; retrieve them via the Exa API.
3Cited by20 opinions
- Fidelity-Philadelphia Trust Co. v. SmithSupreme Court of the United States · 1958
- Conway v. GlennCourt of Appeals for the Sixth Circuit · 1952
- Hutchinson v. CommissionerUnited States Tax Court · 1953
- Seward's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1947
- Bohnen v. HarrisonCourt of Appeals for the Seventh Circuit · 1952
15 more not listed; retrieve them via the Exa API.