Sharpe v. Commissioner
United States Board of Tax Appeals
Petitioner's maternal grandfather created a testamentary trust giving the net income thereof to his widow and children without limitation of time and without gift over of the corpus.
Read the full summary
Petitioner's maternal grandfather created a testamentary trust giving the net income thereof to his widow and children without limitation of time and without gift over of the corpus. Held, that petitioner's mother had a vested interest in here father's estate, the value of which was properly includable in her gross estate under section 302(a) of the Revenue Act of 1926; Held, further, that the deficiency was correctly and timely asserted against petitioner as the sole transferee of the assets of her mother's estate.
1Opinion of the Court
*512OPINION.
Arnold :
Section. 302 of the Revenue Act of 1926 provides that the value of a decedent’s gross estate shall be determined by including the value at the time of his death of all property, real or personal, tangible or intangible, wherever situated, to the extent of the interest therein of the decedent at the time of his death.
The respondent has determined that Fannie G. Dixon, at the time of her death, had a vested interest in the principal of her father’s estate valued at $147,353.54, and that she had a vested interest in coal properties of her father’s estate valued at $456,597. In…
2Cases cited9 opinions
- Chase National Bank v. United StatesSupreme Court of the United States · 1929
- Smith T. v. BellSupreme Court of the United States · 1832
- Estate of TysonSupreme Court of Pennsylvania · 1899
- Byrne's EstateSupreme Court of Pennsylvania · 1935
- Burnet v. PorterSupreme Court of the United States · 1931
4 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- Sharpe v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1939
- Sharpe v. CommissionerUnited States Board of Tax Appeals · 1938