Legal Opinion
Commissioner of Int. Rev. v. Bridgeport City Trust Co.
Court of Appeals for the Second Circuit
Decided December 15, 1941No. 8PublishedCited by 16 opinions
1Opinion of the Court
AUGUSTUS N. HAND, Circuit Judge.
On January 10, 1929, the decedent, Noyés E. Ailing, transferred in trust certain securities of a fair market value as of the date of his death on June 19, 1934, of $138,735.12 for purposes named in the trust instrument. The trust was not created in contemplation of death and under the law of Connecticut, where it took effect, did not violate the rule against perpetuities. Its provisions so far as pertinent to the present case were as follows:
“1. * * * (a) To pay the net income in quarterly installments unto my daughters, Edna Ailing Doherty, of Bridgeport,…
2Cases cited5 opinions
- Helvering v. HelmholzSupreme Court of the United States · 1935
- Guggenheim v. HelveringCourt of Appeals for the Second Circuit · 1941
- Adriance v. HigginsCourt of Appeals for the Second Circuit · 1940
- Packer's Estate (No. 2)Supreme Court of Pennsylvania · 1927
- Helvering v. HelmholzCourt of Appeals for the D.C. Circuit · 1934
3Cited by16 opinions
- Commissioner v. Estate of HolmesSupreme Court of the United States · 1946
- Industrial Trust Co. v. Commissioner of Internal Rev.Court of Appeals for the First Circuit · 1947
- Archbold Van Beuren v. Martin M. McLoughlin (Former Acting Collector of Internal Revenue), DefendnatsCourt of Appeals for the First Circuit · 1959
- Estate of Skifter v. CommissionerUnited States Tax Court · 1971
- Commissioner of Internal Rev. v. Hofheimer's EstateCourt of Appeals for the Second Circuit · 1945
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