Conant v. Commissioner
United States Tax Court
In 1939 petitioner established four trusts and named his wife principal beneficiary in each. He transferred to the four trusts a life insurance policy on his own life and shares of stock in a corporation, some of which shares were pledged to secure petitioner's personal indebtedness. In the taxable years 1940 and 1941, the trustee, upon the direction of the primary beneficiary, paid the premiums on the insurance policy and also paid off the indebtedness.
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In 1939 petitioner established four trusts and named his wife principal beneficiary in each. He transferred to the four trusts a life insurance policy on his own life and shares of stock in a corporation, some of which shares were pledged to secure petitioner's personal indebtedness. In the taxable years 1940 and 1941, the trustee, upon the direction of the primary beneficiary, paid the premiums on the insurance policy and also paid off the indebtedness. Each trust invested the wife with power "to cancel or revoke this trust at any time, in whole or in part," and in the event of such…
1Opinion of the Court
OPINION.
Keen, Judge:
Petitioner created four trusts, with his wife as primary beneficiary of each. She was given the absolute power to cancel the trusts at any time and to take over their corpus and undistributed income. The income-producing corpus of the trusts consisted of 700 shares of corporate stock owned by petitioner at the time the trusts were created. Of this stock, 370 shares were at that time pledged by petitioner to a business associate to secure the repayment of some $37,000 which petitioner had borrowed. In 1940 the trust received dividends from the stock in the total amount of…
Also in this document: Dissent.
2Cases cited3 opinions
- Mallinckrodt v. CommissionerUnited States Tax Court · 1943
- Driscoll v. CommissionerUnited States Tax Court · 1944
- Newman v. CommissionerUnited States Tax Court · 1945
3Cited by9 opinions
- Furman v. CommissionerUnited States Tax Court · 1966
- Kieckhefer v. CommissionerUnited States Tax Court · 1950
- Wiles v. CommissionerUnited States Tax Court · 1972
- Conant v. CommissionerUnited States Tax Court · 1946
- Furman v. CommissionerUnited States Tax Court · 1966
4 more not listed; retrieve them via the Exa API.