National City Bank v. Commissioner
United States Tax Court
Decedent in 1921, 1924, and 1925 conveyed certain property to three irrevocable trusts, reserving to himself and his wife the income for life, with income payable upon his death and the death of his wife to his daughter and upon her death to his grandson.
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Decedent in 1921, 1924, and 1925 conveyed certain property to three irrevocable trusts, reserving to himself and his wife the income for life, with income payable upon his death and the death of his wife to his daughter and upon her death to his grandson. The trusts were to continue for the lives of his daughter and his grandson, and the trusts provided that upon their termination, if he were still living, the corpus should revert to decedent; but in case decedent or his wife did not survive the daughter and grandson, the trust corpus was to be paid to the children of the said grandson then…
1Opinion of the Court
The National City Bank of New York, as Trustee under an Agreement with Charles F. Loudon, Dated October 4, 1921, Petitioner, et al., 1 v. Commissioner of Internal Revenue, Respondent
National City Bank v. Commissioner
Docket Nos. 5941, 5944, 5960, 5962
United States Tax Court
7 T.C. 485; 1946 U.S. Tax Ct. LEXIS 116;
July 31, 1946, Promulgated
Decision will be entered under Rule 50.
Decedent in 1921, 1924, and 1925 conveyed certain property to three irrevocable trusts, reserving to himself and his wife the income for life, with income payable upon his death and the death of his wife to his daughter…
2Cases cited8 opinions
- Hassett v. WelchSupreme Court of the United States · 1938
- May v. HeinerSupreme Court of the United States · 1930
- Fidelity-Philadelphia Trust Co. v. RothensiesSupreme Court of the United States · 1945
- Commissioner v. Estate of FieldSupreme Court of the United States · 1945
- Frances Biddle Trust v. CommissionerUnited States Tax Court · 1944
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