Legal Opinion

Estate of Wolf v. Commissioner

United States Tax Court

Decided December 12, 1957No. Docket No. 58662Published

1. The value of payments due decedent's wife on his death as a result of his naming her beneficiary of pension plans and a profit-sharing trust created by his employers in which he had enforceable vested rights is includible in his gross estate.

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1. The value of payments due decedent's wife on his death as a result of his naming her beneficiary of pension plans and a profit-sharing trust created by his employers in which he had enforceable vested rights is includible in his gross estate. Sec. 811 (a) and (f) (2), I. R. C. 1939. 2. Petitioners have failed to prove that decedent, after assigning to his wife an insurance policy on his life which named her as beneficiary, did not continue to pay the premiums indirectly; accordingly, the face amount of the policy is includible in his gross estate. Sec. 811 (g) (2), I. R. C. 1939. 3. (a)…

1Opinion of the Court

Estate of Charles B. Wolf, Charles S. Wolf, Frances G. Wolf, Executors, Petitioner, v. Commissioner of Internal Revenue, Respondent

Estate of Wolf v. Commissioner

Docket No. 58662

United States Tax Court

29 T.C. 441; 1957 U.S. Tax Ct. LEXIS 23;

December 12, 1957, Filed

Decision will be entered under Rule 50.

1. The value of payments due decedent's wife on his death as a result of his naming her beneficiary of pension plans and a profit-sharing trust created by his employers in which he had enforceable vested rights is includible in his gross estate. Sec. 811 (a) and (f) (2), I. R. C. 1939.

2.…

2Cases cited13 opinions

  1. United States v. JacobsSupreme Court of the United States · 1939
  2. Dimock v. CorwinCourt of Appeals for the Second Circuit · 1938
  3. Dimock v. CorwinDistrict Court, E.D. New York · 1937
  4. Estate of Salt v. CommissionerUnited States Tax Court · 1951
  5. Wolfsen v. SmythCourt of Appeals for the Ninth Circuit · 1955

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