Estate of Regester v. Commissioner
United States Tax Court
Decedent owned a life estate in the income of certain trust property and also possessed a special power of appointment, exercisable inter vivos or by will, over the corpus. She exercised the special power of appointment during her lifetime. Held, decedent made a gift equal to the present value of the life income interest in the trust. Self v. United States, 135 Ct. Cl. 371, 142 F. Supp. 939 (1956), not followed.
1Opinion of the Court
OPINION
Cohen, Judge:
This case was submitted fully stipulated, and the stipulations of facts are incorporated herein by this reference. Charles Regester (petitioner) was a resident of Arizona at the time the petition herein was filed, and he is the personal representative of the Estate of Ruth B. Regester (decedent). The issue for decision is whether decedent made a taxable gift of her life interest in the income of a trust when she transferred the corpus of the trust through the exercise of a special power of appointment.
George L. Bignell, a resident of Michigan, died on September 29,1973.…
2Cases cited7 opinions
- Bailey, Collector of Internal Revenue v. GeorgeSupreme Court of the United States · 1922
- Commissioner of Internal Revenue v. WalstonCourt of Appeals for the Fourth Circuit · 1948
- Hrobon v. CommissionerUnited States Tax Court · 1964
- Walston v. CommissionerUnited States Tax Court · 1947
- Self v. United StatesUnited States Court of Claims · 1956
2 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Estate of Regester v. CommissionerUnited States Tax Court · 1984