Igleheart v. Commissioner
United States Board of Tax Appeals
1. Certain transfers involved herein were made in contemplation of death. 2. Where the value of transfers made by a decedent during his lifetime is to be included in his gross estate for the purposes of the Federal estate tax, it is not unconstitutional to include in the gross estate the value of such property as at the date of the decedent's death rather than as at the date of the transfers. 3. An obligation incurred by executors for the perpetual care of a cemetery lot,…
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1. Certain transfers involved herein were made in contemplation of death. 2. Where the value of transfers made by a decedent during his lifetime is to be included in his gross estate for the purposes of the Federal estate tax, it is not unconstitutional to include in the gross estate the value of such property as at the date of the decedent's death rather than as at the date of the transfers. 3. An obligation incurred by executors for the perpetual care of a cemetery lot, where the estate is being administered in the State of Florida, held not deductible as a funeral expense. 4. Certain life…
1Opinion of the Court
*899OPINION.
Van Fossan:
For the purposes of our discussion the questions to be determined herein may be grouped as follows:
I. Were certain transfers made by the decedent prior to his death made in contemplation of or intended to take effect in possession or enjoyment at or after the decedent’s death?
II. Is section 302 (c) of the Revenue Act of 1926, in so far as concerns the so-called “conclusive presumption” thereof, constitutional ?
III. Should there be included in the gross estate the value, at the date of decedent’s death, of certain transfers made by him, where the value at the date of death…
2Cases cited19 opinions
- Knowlton v. MooreSupreme Court of the United States · 1900
- United States v. WellsSupreme Court of the United States · 1931
- Nichols v. CoolidgeSupreme Court of the United States · 1927
- Chase National Bank v. United StatesSupreme Court of the United States · 1929
- Heiner v. DonnanSupreme Court of the United States · 1932
14 more not listed; retrieve them via the Exa API.
3Cited by17 opinions
- Hull v. CommissionerUnited States Tax Court · 1962
- Howell v. CommissionerUnited States Tax Court · 1981
- Reese v. CommissionerUnited States Board of Tax Appeals · 1934
- Brown v. CommissionerUnited States Board of Tax Appeals · 1934
- Estate of Drake v. CommissionerUnited States Tax Court · 1977
12 more not listed; retrieve them via the Exa API.