Sweeney v. Commissioner
United States Tax Court
1. Decedent created a trust of which his daughter was beneficiary, and she was required to join him in any termination of the trust. They so terminated it, and the corpus was by their direction delivered to her immediately after creation of another trust by her with the same corpus. Decedent was life beneficiary of the income of both trusts.
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1. Decedent created a trust of which his daughter was beneficiary, and she was required to join him in any termination of the trust. They so terminated it, and the corpus was by their direction delivered to her immediately after creation of another trust by her with the same corpus. Decedent was life beneficiary of the income of both trusts. Held, that decedent was grantor of the second trust, and the value of the corpus was properly included in his gross estate. 2. Decedent in 1923 set up a trust which was subject to modification or revocation by him. On December 23, 1932, he modified it to…
1Opinion of the Court
Estate of George W. Sweeney, Alice S. Mergenthaler, et al., Executors, Petitioner, v. Commissioner of Internal Revenue, Respondent
Sweeney v. Commissioner
Docket No. 1955
United States Tax Court
4 T.C. 265; 1944 U.S. Tax Ct. LEXIS 31;
October 31, 1944, Promulgated
Decision will be entered for the respondent.
1. Decedent created a trust of which his daughter was beneficiary, and she was required to join him in any termination of the trust. They so terminated it, and the corpus was by their direction delivered to her immediately after creation of another trust by her with the same corpus. Decedent was…
2Cases cited7 opinions
- Reinecke v. Northern Trust Co.Supreme Court of the United States · 1929
- Chase National Bank v. United StatesSupreme Court of the United States · 1929
- Burnet v. GuggenheimSupreme Court of the United States · 1933
- Porter v. CommissionerSupreme Court of the United States · 1933
- Helvering v. City Bank Farmers Trust Co.Supreme Court of the United States · 1935
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