Vernon v. Commissioner
United States Tax Court
Petitioner Mary E. Vernon placed stock in trust. Her mother was the sole net income beneficiary. Upon her mother's death or the expiration of 10 years, the trust was to terminate and petitioner was to receive the trust principal. Held, value of gift determined under method contained in sec. 25.2512-9(a)(1)(i), Gift Tax Regs., which provides that the value of the gift is the value of the property transferred less the value of the donor's retained interest.
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Petitioner Mary E. Vernon placed stock in trust. Her mother was the sole net income beneficiary. Upon her mother's death or the expiration of 10 years, the trust was to terminate and petitioner was to receive the trust principal. Held, value of gift determined under method contained in sec. 25.2512-9(a)(1)(i), Gift Tax Regs., which provides that the value of the gift is the value of the property transferred less the value of the donor's retained interest. Held, further, annual interest rate of 6 percent, reflected in tables used in valuing interests under sec. 25.2512-9(e), Gift Tax Regs., is…
1Opinion of the Court
Wiles, Judge:
Respondent determined gift tax deficiencies for the calendar quarter ending December of 1971 of $998.47 for John H. Vernon and $2,015.36 for Mary E. Vernon. The issue is whether, in valuing the gift in issue, the valuation method contained in section 25.2512-9(a)(l)(i) and (e), Gift Tax Regs., should be used or whether another valuation method is more acceptable.
FINDINGS OF FACT
Some facts were stipulated and are found accordingly.
Petitioners, husband and wife, lived in Vail, Colo., when they filed their petitions herein. Petitioners filed gift tax returns for the calendar quarter…
2Cases cited10 opinions
- Marie H. Hamm v. Commissioner of Internal Revenue, William Hamm, Jr. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
- Weller v. CommissionerUnited States Tax Court · 1962
- Hanley v. United StatesUnited States Court of Claims · 1945
- Fred A. Berzon v. Commissioner of Internal Revenue, Gertrude Berzon v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1976
- Berzon v. CommissionerUnited States Tax Court · 1975
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- O'Reilly v. CommissionerUnited States Tax Court · 1990
- ESTATE OF GLADYS J. COOK v. COMMISSIONERUnited States Tax Court · 2001
- Estate of Gribauskas v. CommissionerUnited States Tax Court · 2001
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