Glen v. Commissioner
United States Tax Court
Decedent entered into a property settlement agreement with his then wife, Jane, prior to divorce, in which the wife relinquished all of her rights against decedent including a right under local law to one-third of his personal property outright upon divorce. Subsequently decedent was divorced from Jane by a court decree which made no mention of the property settlement agreement.
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Decedent entered into a property settlement agreement with his then wife, Jane, prior to divorce, in which the wife relinquished all of her rights against decedent including a right under local law to one-third of his personal property outright upon divorce. Subsequently decedent was divorced from Jane by a court decree which made no mention of the property settlement agreement. Pursuant to the property settlement agreement decedent created three trusts for the benefit of himself, his son, and Jane; he retained life estates in two of these trusts which were included in his estate for estate…
1Opinion of the Court
Hoyt, Judge:
Respondent determined a deficiency of $120,123.90 in the estate tax of the Estate of Robert Rodger Glen, deceased, and also asserted transferee liability in the same amount against Morgan Guaranty Trust Co. of New York as trustee of an inter vivos trust created in 1938 by Robert Rodger Glen, deceased.
Separate petitions were filed by the executrix of the decedent’s estate and by Morgan Guaranty Trust Co. of New York (hereinafter sometimes referred to as Morgan Guaranty) as trustee and transferee. The two proceedings initiated thereby have been consolidated for trial, briefing, and…
2Cases cited23 opinions
- Estate of Sanford v. CommissionerSupreme Court of the United States · 1939
- United States v. DavisSupreme Court of the United States · 1962
- Merrill v. FahsSupreme Court of the United States · 1945
- Harris v. CommissionerSupreme Court of the United States · 1950
- McMurtry v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1953
18 more not listed; retrieve them via the Exa API.
3Cited by47 opinions
- CWT Farms, Inc. v. CommissionerUnited States Tax Court · 1982
- Nelson v. CommissionerUnited States Tax Court · 1966
- Estate of Carli v. Comm'rUnited States Tax Court · 1985
- Estate of James H. Waters, Jr., Deceased William Roger Waters and John B. McMillan Co-Executors v. Commissioner of the Internal Revenue ServiceCourt of Appeals for the Fourth Circuit · 1995
- Hartshorne v. CommissionerUnited States Tax Court · 1967
42 more not listed; retrieve them via the Exa API.