Hooper v. Commissioner
United States Board of Tax Appeals
1. Decedent's death occurred in 1933. In 1932, being heavily in debt, he had transferred substantially all of his property, including his life insurance, to a trust, the trustee being authorized to collect his (decedent's) salary of $45,000 per annum and to use it and all other trust income to pay insurance premiums, to pay decedent's wife from $14,000 to $16,000 per annum for family living expenses, to pay off decedent's debts and thereafter to divide the income between…
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1. Decedent's death occurred in 1933. In 1932, being heavily in debt, he had transferred substantially all of his property, including his life insurance, to a trust, the trustee being authorized to collect his (decedent's) salary of $45,000 per annum and to use it and all other trust income to pay insurance premiums, to pay decedent's wife from $14,000 to $16,000 per annum for family living expenses, to pay off decedent's debts and thereafter to divide the income between decedent and his wefe. Held, that the value of the property transferred to the trust must be included in decedent's gross…
1Opinion of the Court
*123OPINION.
Mellott:
The following schedule shows the respondent’s method of computing the net estate under the 1932 Act:
Gross Estate Returned_$50,680.00 Add:(a) Property as to which there is no controversy over value_ 3,142.37(b) Proceeds of life insurance policies_ 132,639.31(e) Value of 3,613 shares of William E. Hooper & Sons Co. stock at $100 per share_ 361,300.00
Total gross estate- 547,761. 68
Deductions allowable_ 279,131.92
Taxable Net Estate- 268,629.76
Petitioner contends that none of the property added by the respondent is includable in gross estate; that in any event the value of the…
2Cases cited5 opinions
- Lucas v. EarlSupreme Court of the United States · 1930
- United States v. WellsSupreme Court of the United States · 1931
- Douglas v. WillcutsSupreme Court of the United States · 1935
- Hassett v. WelchSupreme Court of the United States · 1938
- Helvering v. BullardSupreme Court of the United States · 1938
3Cited by34 opinions
- The Estate of Mary Frances Smith Bright, Deceased, by H. R. Bright, Independent v. United StatesCourt of Appeals for the Fifth Circuit · 1981
- Estate of Andrews v. CommissionerUnited States Tax Court · 1982
- Ward v. CommissionerUnited States Tax Court · 1986
- United States v. Curtis L. Parker and Martha ParkerCourt of Appeals for the Fifth Circuit · 1967
- Harriet T. Righter, of the Estate of Jessie H. Righter v. The United StatesUnited States Court of Claims · 1971
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