Wheeler v. Commissioner
United States Tax Court
1. Decedent Raymond Parks Wheeler created an inter vivos trust in 1940 to which he transferred certain securities and made the Hartford-Connecticut Trust Company of Hartford, Connecticut, trustee. He was made the income beneficiary for life and at his death his wife, Evelyn King Wheeler, and his children were to receive certain benefits under the terms of the trust.
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1. Decedent Raymond Parks Wheeler created an inter vivos trust in 1940 to which he transferred certain securities and made the Hartford-Connecticut Trust Company of Hartford, Connecticut, trustee. He was made the income beneficiary for life and at his death his wife, Evelyn King Wheeler, and his children were to receive certain benefits under the terms of the trust. The trust was revocable and upon the death of the settlor in 1951, the value of the trust assets was included in decedent's gross estate. In the estate tax return a marital deduction of $ 200,462.83 was claimed. This deduction was…
1Opinion of the Court
OPINION.
Black, Judge:
The Commissioner in his determination of the deficiency disallowed all of the marital .deduction claimed on the estate tax return. However, he now concedes that petitioner is entitled to a marital deduction of $3,500 on account of the proceeds of the insurance policies paid to Evelyn on the death of the decedent. Effect will be given to this concession in a computation under Rule 50.
Issue (a).
The first issue which we have to decide is stated by petitioner in assignment of error (a), as follows:(a) The Commissioner erroneously determined that the trust assets included in…
2Cases cited4 opinions
- Pipe v. CommissionerUnited States Tax Court · 1954
- Hoffenberg v. CommissionerUnited States Tax Court · 1954
- Roy B. Thompson, Jr., of the Will of Roy B. Thompson, Deceased v. Earl R. Wiseman, District Director of Internal RevenueCourt of Appeals for the Tenth Circuit · 1956
- Hohensee v. CommissionerUnited States Tax Court · 1956
3Cited by15 opinions
- Rose Gelb, Victor Edwin Gelb, Manufacturers Trust Company, Executors, of the Estate of Harry Gelb v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1962
- Estate of Weisberger v. CommissionerUnited States Tax Court · 1957
- Estate of Wycoff v. CommissionerUnited States Tax Court · 1973
- Noble v. CommissionerUnited States Tax Court · 1959
- Benjamin v. CommissionerUnited States Tax Court · 1965
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