Estate of Christ v. Comm'r
United States Tax Court
Decedent was a widow and a resident of California. She died on Dec. 2, 1961. During the probate of her husband's will, subsequent to his death on Apr. 16, 1952, decedent made an election, effective Sept. 30, 1953, whereby she agreed to transfer all of her share of community property to a testamentary trust created pursuant to the will. The deceased husband's share of the community property was also transferred to the trust.
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Decedent was a widow and a resident of California. She died on Dec. 2, 1961. During the probate of her husband's will, subsequent to his death on Apr. 16, 1952, decedent made an election, effective Sept. 30, 1953, whereby she agreed to transfer all of her share of community property to a testamentary trust created pursuant to the will. The deceased husband's share of the community property was also transferred to the trust. The trust provided that the widow was to be the sole beneficiary of a life interest, with the remainder to be paid to the spouses' son upon the termination of the trust at…
1Opinion of the Court
OPINION
Income Tax Oases: Dochet Nos. 95357, 13lfB-6i
The basic issues in the income tax cases are whether Daisy acquired the life interest in the portion of the trust attributable to Andrew’s share of the community property (41.307 percent) in a transaction which constituted a purchase, and, if so, whether she is entitled to amortization deductions in the years in issue for the cost of acquiring the life interest.2
Petitioner contends that Daisy acquired the life interest in the portion of the trust attributable to Andrew’s community property transferred to the trust in a transaction which…
2Cases cited32 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Helvering v. CliffordSupreme Court of the United States · 1940
- Ithaca Trust Co. v. United StatesSupreme Court of the United States · 1929
- Helvering v. ButterworthSupreme Court of the United States · 1933
- Commissioner v. WemyssSupreme Court of the United States · 1945
27 more not listed; retrieve them via the Exa API.
3Cited by104 opinions
- Parker v. CommissionerUnited States Tax Court · 1986
- Estate of Newhouse v. CommissionerUnited States Tax Court · 1990
- Estate of Daisy F. Christ, Deceased, Robert Johnson Christ v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1973
- Estate of Di Rezza v. CommissionerUnited States Tax Court · 1982
- Trans City Life Ins. Co. v. CommissionerUnited States Tax Court · 1996
99 more not listed; retrieve them via the Exa API.