Legal Opinion
Humphrey's Estate v. Commissioner of Internal Revenue
Court of Appeals for the Fifth Circuit
Decided July 2, 1947No. 11920PublishedCited by 22 opinions
1Opinion of the Court
SIBLEY, Circuit Judge.
The case relates to the estate taxes of Albert P. Humphrey, who died testate February 23, 1942, the reported value of his estate being $185,475. On January 18, 1941, within two years prior to his death, decedent and his wife each made cash gifts to their two sons of $40,000. The Commissioner included this $40,000 in the gross estate of decedent and taxed it. The Tax Court sustained this action, finding-that the $40,000 was as a matter of fact transferred in contemplation of death, because the evidence not only did not rebut the statutory presumption stated in Internal…
2Cases cited1 opinion
- Allen v. Trust Co. of Ga.Supreme Court of the United States · 1946
3Cited by22 opinions
- Carlos and Jacqueline Marcello v. Commissioner of Internal Revenue, Joseph, Jr. And Anastasia Marcello v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
- Estate of Gerard v. CommissionersUnited States Tax Court · 1972
- Commissioner of Internal Revenue v. Gidwitz' Estate Gidwitz' Estate v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1952
- Estate of Coleman v. CommissionerUnited States Tax Court · 1969
- Burns v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1949
17 more not listed; retrieve them via the Exa API.