Geller v. Commissioner
United States Tax Court
1. The petitioner executed a relinquishment of reserved trust powers and filed consent, under section 1000 (e), Internal Revenue Code, that the transfer in trust be treated as a completed gift in the year when made.
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1. The petitioner executed a relinquishment of reserved trust powers and filed consent, under section 1000 (e), Internal Revenue Code, that the transfer in trust be treated as a completed gift in the year when made. Held, that such relinquishment and consent did not determine that gifts made in the trust instrument were of present interests. 2. The trust indenture provided gifts of corpus, to take effect only after death of settlor's wife, with other contingencies as to survivorship among the donees. Held, there were no gifts of present interest in trust corpus; held, further, that gifts of…
1Opinion of the Court
Andrew Geller, Petitioner, v. Commissioner of Internal Revenue, Respondent
Geller v. Commissioner
Docket No. 11369
United States Tax Court
9 T.C. 484; 1947 U.S. Tax Ct. LEXIS 92;
September 29, 1947, Promulgated
Decision will be entered for the respondent.
1. The petitioner executed a relinquishment of reserved trust powers and filed consent, under section 1000 (e), Internal Revenue Code, that the transfer in trust be treated as a completed gift in the year when made. Held, that such relinquishment and consent did not determine that gifts made in the trust instrument were of present interests.
2. The…
2Cases cited11 opinions
- Estate of Sanford v. CommissionerSupreme Court of the United States · 1939
- United States v. PelzerSupreme Court of the United States · 1941
- Merchants Nat. Bank of Boston v. CommissionerSupreme Court of the United States · 1943
- Fondren v. CommissionerSupreme Court of the United States · 1945
- Ryerson v. United StatesSupreme Court of the United States · 1941
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