Legal Opinion

Estate of Halberstam v. Commissioner

United States Tax Court

Decided November 30, 1954No. Docket No. 48492Unpublished

The decedent reserved the right to appoint by will the remaindermen of an inter vivos trust. Held: That the value of the trust corpus is includible in decedent's estate under the provisions of sections 811(c) and 811(d)(1), 1939 Code.

1Opinion of the Court

Estate of Antonina Toni Halberstam, also known as Toni Halberstam, Deceased, Marcel Klarmann, Executor v. Commissioner.

Estate of Halberstam v. Commissioner

Docket No. 48492.

United States Tax Court

T.C. Memo 1954-208; 1954 Tax Ct. Memo LEXIS 37; 13 T.C.M. (CCH) 1081; T.C.M. (RIA) 54318;

November 30, 1954, Filed

The decedent reserved the right to appoint by will the remaindermen of an inter vivos trust. Held: That the value of the trust corpus is includible in decedent's estate under the provisions of sections 811(c) and 811(d)(1), 1939 Code.

Frank Reiter, Esq., 101 West 30th Street, New York, N.Y.,…

2Cases cited5 opinions

  1. Fidelity-Philadelphia Trust Co. v. RothensiesSupreme Court of the United States · 1945
  2. Sinclaire v. CommissionerUnited States Tax Court · 1949
  3. Korn v. CommissionerUnited States Board of Tax Appeals · 1937
  4. Bowers v. CommissionerUnited States Board of Tax Appeals · 1936
  5. Holderness v. CommissionerUnited States Board of Tax Appeals · 1935

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