Estate of Talbot v. Commissioner
United States Tax Court
Decedent transferred $ 253,416.35 worth of stock in a family owned corporation to his three children and their families within 3 years of his death. Held, because the transfers were motivated by a concern for the financial security of his children and by a desire to minimize decedent's income and gift taxes, the transfers were not in contemplation of death within the meaning of sec. 2035, I.R.C. 1954.
1Opinion of the Court
ESTATE OF C. FINLEY TALBOT, DECEASED, CHARLES FINLEY TALBOT, JR. AND RUTH M. TALBOT, ADMINISTRATORS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Estate of Talbot v. Commissioner
Docket No. 10811-80.
United States Tax Court
T.C. Memo 1981-560; 1981 Tax Ct. Memo LEXIS 183; 42 T.C.M. (CCH) 1263; T.C.M. (RIA) 81560;
September 29, 1981.
Decedent transferred $ 253,416.35 worth of stock in a family owned corporation to his three children and their families within 3 years of his death. Held, because the transfers were motivated by a concern for the financial security of his children and by a…
2Cases cited16 opinions
- United States v. WellsSupreme Court of the United States · 1931
- Allen v. Trust Co. of Ga.Supreme Court of the United States · 1946
- Estate of Ford v. CommissionerUnited States Tax Court · 1969
- McCaughn v. Real Estate Land Title & Trust Co.Supreme Court of the United States · 1936
- Wilson v. CommissionerUnited States Tax Court · 1949
11 more not listed; retrieve them via the Exa API.