Legal Opinion

Raegner v. Commissioner

United States Board of Tax Appeals

Decided February 27, 1934No. Docket No. 49078PublishedCited by 3 opinions

1. ESTATE TAX - WHETHER DECEDENT DIED POSSESSED OF REVERSIONARY INTERESTS IN NINE DIFFERENT TRUSTS. - Decedent created nine trusts. The income of one trust was payable to decedent's wife during her life; upon her death to his children and the issue of any deceased child, per stirpes; upon termination of the trust, the corpus was to be divided among decedent's then living children and the issue of any deceased child, per stirpes.

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1. ESTATE TAX - WHETHER DECEDENT DIED POSSESSED OF REVERSIONARY INTERESTS IN NINE DIFFERENT TRUSTS. - Decedent created nine trusts. The income of one trust was payable to decedent's wife during her life; upon her death to his children and the issue of any deceased child, per stirpes; upon termination of the trust, the corpus was to be divided among decedent's then living children and the issue of any deceased child, per stirpes. The income of the remaining eight trusts was payable, in each trust, to a specified child of decedent for life, with remainders substantially the same as in the first…

1Opinion of the Court

OPINION.

Black: This proceeding is for the redetermination of a deficiency in Federal estate tax in the amount of $10,968.91. The amount of the deficiency protested is $2,933.01, and is based on the following assignment of error:

The taxing by the Commissioner of the principal amounting to $33,330.00 of a certain trust deed and the income thereof, dated December 9th, 1925, made by the Decedent for the benefit of his son, Louis C. Raegner, Jr., as beneficiary.

*1244At the hearing the respondent filed an amended answer in which he made claim for an additional deficiency based upon the following…

2Cases cited6 opinions

  1. Reinecke v. SmithSupreme Court of the United States · 1933
  2. Wallace v. CommissionerUnited States Board of Tax Appeals · 1933
  3. Stetson v. CommissionerUnited States Board of Tax Appeals · 1932
  4. Lit v. CommissionerUnited States Board of Tax Appeals · 1933
  5. Fletcher v. CommissionerUnited States Board of Tax Appeals · 1933

1 more not listed; retrieve them via the Exa API.

3Cited by3 opinions

  1. Fish v. CommissionerUnited States Board of Tax Appeals · 1941
  2. Helvering v. HallockSupreme Court of the United States · 1940
  3. Raegner v. CommissionerUnited States Board of Tax Appeals · 1934

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