Deal v. Commissioner
United States Tax Court
Petitioner, on December 29, 1952, transferred land with a market value of $ 66,000 in trust. The trustees in their discretion were to pay to the petitioner the income for life in such amounts as would care for her reasonable needs. The undistributed income was to be added to the corpus. Upon petitioner's death the petitioner's four daughters were to share in the income and corpus.
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Petitioner, on December 29, 1952, transferred land with a market value of $ 66,000 in trust. The trustees in their discretion were to pay to the petitioner the income for life in such amounts as would care for her reasonable needs. The undistributed income was to be added to the corpus. Upon petitioner's death the petitioner's four daughters were to share in the income and corpus. On the same day as the transfer in trust, the petitioner's four daughters executed $ 41,000 in non-interest-bearing demand notes payable to petitioner. The petitioner canceled, without consideration, the $ 41,000 in…
1Opinion of the Court
OPINION.
Black, Judge:
In controversy herein is the amount of petitioner’s net gifts for the year 1952. The petitioner reported no net gifts and the respondent determined $36,000 in net gifts.
The salient facts can be summarized as follows:
The petitioner, the owner of an undivided 64 per cent interest in a tract of land, purchased the other 36 per cent on December 15,1952. The value of the entire tract on that day was $66,000. The Commissioner has determined that to be the value of the land on that date and there is no evidence in the record to refute it. On December 29, 1952, petitioner…
2Cases cited1 opinion
- United States v. PelzerSupreme Court of the United States · 1941
3Cited by25 opinions
- Estate of Reynolds v. CommissionerUnited States Tax Court · 1970
- Estate of Lydia G. Maxwell, Deceased First National Bank of Long Island Victor C. McCuaig Jr., Executors v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1993
- Story v. CommissionerUnited States Tax Court · 1962
- Estate of Maxwell v. CommissionerUnited States Tax Court · 1992
- Daniel J. Mahoney Jr., of the Estate of James M. Cox Jr. v. United StatesCourt of Appeals for the Sixth Circuit · 1987
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