Weller v. Commissioner
United States Tax Court
1. Value of gifts of the right to receive income from a 34-percent interest in a partnership in trust for a period of 10 years and 90 days, the entire principal of the trusts to revert to the settlors on termination of the trusts, determined under section 25,2512-5(c), Gift Tax Regs. 2. Sale by Carl of a 2-percent interest in partnership to Beyer, an unrelated person, for less than the stipulated fair market value of the interest did not constitute a taxable gift by Carl to…
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1. Value of gifts of the right to receive income from a 34-percent interest in a partnership in trust for a period of 10 years and 90 days, the entire principal of the trusts to revert to the settlors on termination of the trusts, determined under section 25,2512-5(c), Gift Tax Regs. 2. Sale by Carl of a 2-percent interest in partnership to Beyer, an unrelated person, for less than the stipulated fair market value of the interest did not constitute a taxable gift by Carl to Beyer, 3. Gifts in trust to minor children held to qualify for the annual exclusion under section 2503(c), I.R.C. 1954.
1Opinion of the Court
Carl E. Weller, Petitioner, v. Commissioner of Internal Revenue, Respondent. Emily I. Weller, Petitioner, v. Commissioner of Internal Revenue, Respondent
Weller v. Commissioner
Docket Nos. 86488, 86489
United States Tax Court
38 T.C. 790; 1962 U.S. Tax Ct. LEXIS 84;
September 10, 1962, Filed
Decisions will be entered under Rule 50.
1. Value of gifts of the right to receive income from a 34-percent interest in a partnership in trust for a period of 10 years and 90 days, the entire principal of the trusts to revert to the settlors on termination of the trusts, determined under section 25,2512-5(c),…
2Cases cited21 opinions
- Ithaca Trust Co. v. United StatesSupreme Court of the United States · 1929
- Commissioner v. WemyssSupreme Court of the United States · 1945
- Fondren v. CommissionerSupreme Court of the United States · 1945
- Commissioner v. DisstonSupreme Court of the United States · 1945
- Commissioner of Internal Revenue v. MarshallCourt of Appeals for the Second Circuit · 1942
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