Estate of Porter v. Commissioner
United States Tax Court
Decedent, approximately 3 weeks before his death, entered into identical contracts with three corporations of which he was an officer and employee, under which as an inducement to the decedent to remain in their employ, the corporations agreed to make certain payments to his surviving spouse or issue if the decedent was in the employ of each of those corporations at his death.
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Decedent, approximately 3 weeks before his death, entered into identical contracts with three corporations of which he was an officer and employee, under which as an inducement to the decedent to remain in their employ, the corporations agreed to make certain payments to his surviving spouse or issue if the decedent was in the employ of each of those corporations at his death. The contracts provided that they were to be binding on the successors, heirs, executors, and administrators of the parties and could not be terminated or altered without the written consent of all parties. Held, the…
1Opinion of the Court
OPINION
Scott, Judge:
The Commissioner determined a deficiency in the Federal estate tax of the Estate of Bernard L. Porter, deceased, in the amount of $12,041.89. Petitioners, the administrators of the estate, all were residents of Worcester, Mass., at the date of the filing of the petition in this case. The estate tax return was filed with the district director of internal revenue at Boston, Mass.
The issues presented for decision are:(1) Whether certain contracts between the decedent and his employers gave rise to an interest in property which was transferred by decedent under such…
2Cases cited26 opinions
- Chase National Bank v. United StatesSupreme Court of the United States · 1929
- United States v. JacobsSupreme Court of the United States · 1939
- Lehman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1940
- United States v. Estate of GraceSupreme Court of the United States · 1969
- Piper v. ChildsMassachusetts Supreme Judicial Court · 1935
21 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Estate of Kopperman v. CommissionerUnited States Tax Court · 1978
- Estate of Bernard L. Porter, Deceased v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1971
- Estate of Kleemeier v. CommissionerUnited States Tax Court · 1972
- Estate of Levin v. CommissionerUnited States Tax Court · 1988
- Estate of Kleemeier v. CommissionerUnited States Tax Court · 1972
2 more not listed; retrieve them via the Exa API.