Estate of Halbach v. Commissioner
United States Tax Court
Decedent received a remainder interest in a trust established in 1937 by her father's will. On Apr. 14, 1970, the life tenant of the trust died. On Apr. 19, 1970, decedent disclaimed her interest. Held, decedent's delayed renunciation had the effect of a transfer for purposes of sec. 2035.
1Opinion of the Court
Sterrett, Judge:
Respondent, on April 30,1976, determined a deficiency in petitioner’s estate tax in the amount of $9,619,033.53.1 Due to a severance of the issues raised by petitioner, the sole question for our determination is whether the disclaimer made by Helen Wodell Halbach of her remainder interest in a trust corpus constituted a transfer of property within the meaning of section 2035,1.R.C. 1954.
FINDINGS OF FACT
This case was submitted under Rule 122, Tax Court Rules of Practice and Procedure, hence all of the facts have been stipulated and are so found.
Helen Wodell Halbach (hereinafter…
2Cases cited6 opinions
- Commissioner v. Estate of BoschSupreme Court of the United States · 1967
- Chase National Bank v. United StatesSupreme Court of the United States · 1929
- Brown v. RoutzahnCourt of Appeals for the Sixth Circuit · 1933
- Fuller v. CommissionerUnited States Tax Court · 1961
- Jewett v. CommissionerUnited States Tax Court · 1978
1 more not listed; retrieve them via the Exa API.
3Cited by13 opinions
- Poinier v. CommissionerUnited States Tax Court · 1986
- Cottrell v. CommissionerUnited States Tax Court · 1979
- Estate of Dancy v. CommissionerUnited States Tax Court · 1987
- Estate of Bunn v. United StatesUnited States Court of Claims · 1983
- Poinier v. CommissionerUnited States Tax Court · 1991
8 more not listed; retrieve them via the Exa API.