Spofford v. Commissioner
United States Board of Tax Appeals
1. Certain transfers of real and personal property held not to have been made in contemplation of death. 2. The Commissioner's determination that a transfer of certain bonds was intended to take effect in possession or enjoyment at or after death approved. 3. The provisions of section 402(d) of the Revenue Act of 1918 are not retroactive.
1Opinion of the Court
*1019OPINION.
Littleton: The issue presented by this appeal is whether the Commissioner erred in including in the gross estate of Lucy M. Mills the value at the time of her death of the bonds transferred by her to Florence M. Spofford on or about April 8, 1916, and of the real estate, a joint interest in which she transferred to Florence M. Spofford and which she and Florence M. Spofford held as joint tenants at the time of her death.
The Commissioner contends that the transfers of both the bonds and the real estate were made in contemplation of death, and that 'the transfer of the bonds was not…
2Cases cited7 opinions
- Shwab v. DoyleSupreme Court of the United States · 1922
- Shwab v. DoyleCourt of Appeals for the Sixth Circuit · 1920
- Knox v. McElligottSupreme Court of the United States · 1922
- Safe Deposit & Trust Co. v. TaitDistrict Court, D. Maryland · 1923
- Kissam v. McElligottDistrict Court, S.D. New York · 1920
2 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- Emery v. CommissionerUnited States Board of Tax Appeals · 1930
- Heiner v. DonnanSupreme Court of the United States · 1932
- Spofford v. CommissionerUnited States Board of Tax Appeals · 1926