Taft v. Commissioner
United States Board of Tax Appeals
1. A transfer in trust made solely to avoid annual state property taxes, held, not made in contemplation of death. 2. A transfer in trust in which the settlor reserved the right to income for life and a contingent right to appoint in case of her survival of a beneficiary, which did not occur, held, not one to take effect in possession or enjoyment at or after death and not within section 302(d), Revenue Act of 1926. 3. A claim based upon a contractual promise, partially…
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1. A transfer in trust made solely to avoid annual state property taxes, held, not made in contemplation of death. 2. A transfer in trust in which the settlor reserved the right to income for life and a contingent right to appoint in case of her survival of a beneficiary, which did not occur, held, not one to take effect in possession or enjoyment at or after death and not within section 302(d), Revenue Act of 1926. 3. A claim based upon a contractual promise, partially executed, to transfer an amount to an educational corporation, held, not incurred for an adequate and full consideration in…
1Opinion of the Court
SteRNhageN :
Respondent determined a deficiency of $1,627,585.28 in estate tax. He included in gross estate tbe value of property in a trust created by decedent for tbe benefit of her children, and be disallowed tbe deduction of several amounts paid by her executor because of promises made by decedent during her life.
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Findings of Fact. — Anna Sinton Taft died suddenly on January 31,1931, aged seventy-nine. On March 13,1924, she created an irrevocable trust, naming a New York bank as trustee, to which she *673transferred securities. At the time of her death the value of the trust property was…
2Cases cited10 opinions
- United States v. WellsSupreme Court of the United States · 1931
- Reinecke v. Northern Trust Co.Supreme Court of the United States · 1929
- May v. HeinerSupreme Court of the United States · 1930
- Trinidad v. Sagrada Orden De Predicadores De La Provincia Del Santisimo Rosario De FilipinasSupreme Court of the United States · 1924
- Helvering v. St. Louis Union Trust Co.Supreme Court of the United States · 1935
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3Cited by7 opinions
- Day v. CommissionerUnited States Board of Tax Appeals · 1936
- Estate of Frederick C. Hodgdon v. CommissionerUnited States Tax Court · 1952
- Hays v. CommissionerUnited States Board of Tax Appeals · 1936
- Helvering v. HallockSupreme Court of the United States · 1940
- Kienbusch v. CommissionerUnited States Board of Tax Appeals · 1936
2 more not listed; retrieve them via the Exa API.