Legal Opinion
United States v. O'MALLEY
Supreme Court of the United States
Decided March 24, 1966No. 127PublishedCited by 111 opinions
1Opinion of the CourtJustice White
The Internal Revenue Code of 1939 imposes an estate tax “upon the transfer of the net estate of every decedent.” § 810. The gross estate is to include not only all property “[t]o the extent of the interest therein of the decedent at the time of his death,” § 811 (a), but also, under §811 (e)(1), all property
“To the extent of any interest therein of which the decedent has at any time made a transfer (except in case of a bona fide sale for an adequate and full consideration in money or money's worth), by trust or otherwise—
“(A) in contemplation of his death; or
“(B) under which he has retained…
2Cases cited22 opinions
- Helvering v. HallockSupreme Court of the United States · 1940
- May v. HeinerSupreme Court of the United States · 1930
- Commissioner v. Estate of ChurchSupreme Court of the United States · 1949
- Estate of Spiegel v. CommissionerSupreme Court of the United States · 1949
- Commissioner v. Estate of HolmesSupreme Court of the United States · 1946
17 more not listed; retrieve them via the Exa API.
3Cited by111 opinions
- United States v. ByrumSupreme Court of the United States · 1972
- Peterson Marital Trust v. CommissionerUnited States Tax Court · 1994
- Estate of Bongard v. Comm'rUnited States Tax Court · 2005
- Estate of Bischoff v. CommissionerUnited States Tax Court · 1977
- Harold S. Divine and Rita K. Divine v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1974
106 more not listed; retrieve them via the Exa API.