Pruyn v. Commissioner
United States Tax Court
Transfer of decedent's funds to commercial insurance companies prior to 1931 for purchase with her younger sister of joint and survivor annuities, held to be a transfer intended to take effect at death and as such properly included in decedent's gross estate; held, further, respondent's determination not shown to be erroneous that the amount to be included is replacement cost charged by commercial companies for comparable contracts. Estate of William J. Higgs, 12 T. C. 280.
1Opinion of the Court
Estate of Mary L. Pruyn, Deceased, Nellie K. Pruyn, Executrix, Petitioner, v. Commissioner of Internal Revenue, Respondent
Pruyn v. Commissioner
Docket No. 15236
United States Tax Court
12 T.C. 754; 1949 U.S. Tax Ct. LEXIS 203;
May 12, 1949, Promulgated
Decision will be entered under Rule 50.
Transfer of decedent's funds to commercial insurance companies prior to 1931 for purchase with her younger sister of joint and survivor annuities, held to be a transfer intended to take effect at death and as such properly included in decedent's gross estate; held, further, respondent's determination not shown…
Also in this document: Concurrence; Dissent · Arundell; Dissent · Johnson.
2Cases cited13 opinions
- May v. HeinerSupreme Court of the United States · 1930
- Commissioner v. Estate of ChurchSupreme Court of the United States · 1949
- Commissioner v. WemyssSupreme Court of the United States · 1945
- United States v. RyersonSupreme Court of the United States · 1941
- Merrill v. FahsSupreme Court of the United States · 1945
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