Williams v. Commissioner
United States Board of Tax Appeals
Property conveyed by deed to wife and daughters of the decedent in 1906, although possession and control of it were retained by him until his death in 1925, nevertheless vested title in the grantees as and from the former date; and should not be included in the assets of the decedent's estate in computing Federal estate taxes on same.
1Opinion of the Court
*1080OPINION.
Lansdon:
Petitioners contend that the unrecorded deeds of 1906 passed a present title to the property therein specified to the wife and daughters of the decedent, and that decedent thereafter must be regarded not as the owner thereof, but as the agent of the grantees. The respondent contends that the decedent’s continued possession, control and use of the property and the income therefrom to the date of his death indicate that he did not intend to divest himself of title when he delivered the deeds.
The deficiéncy notice with statement attached does not clearly set forth any specific…
2Cases cited17 opinions
- Reinecke v. Northern Trust Co.Supreme Court of the United States · 1929
- May v. HeinerSupreme Court of the United States · 1930
- Bury v. YoungCalifornia Supreme Court · 1893
- Bias v. ReedCalifornia Supreme Court · 1914
- Moore v. TrottCalifornia Supreme Court · 1912
12 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- McRae v. CommissionerUnited States Board of Tax Appeals · 1934
- Foster v. CommissionerUnited States Board of Tax Appeals · 1932
- Williams v. CommissionerUnited States Board of Tax Appeals · 1932