Frances Biddle Trust v. Commissioner
United States Tax Court
Decedent, during her lifetime, transferred property to an irrevocable trust established for the benefit of her son and his children. The income is to be paid to the son for life and upon his death to his children. When the children reach designated ages their respective shares of the principal are to be paid to them or to their issue per stirpes.
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Decedent, during her lifetime, transferred property to an irrevocable trust established for the benefit of her son and his children. The income is to be paid to the son for life and upon his death to his children. When the children reach designated ages their respective shares of the principal are to be paid to them or to their issue per stirpes. If a child dies before reaching the designated age, or if he dies without issue surviving, his share is to be paid to his brothers and sisters. In the event all of the children die, after the death of decedent's son, or in the event no children or…
1Opinion of the Court
OPINION.
Mellott, Judge:
The petitioners, Sydney G. Biddle and Fidelity-Philadelphia Trust Co., contest respondent’s determination that the trust1 of which they are trustees (Frances Biddle trust) is liable, as a transferee of property of the estate of Frances Biddle, for estate tax in the amount of $1,789.37.
The issues are:(1) Whether the value of the corpus of the trust estate, after deducting the value of the interest of the life tenant, is includible in the gross estate of the decedent as a transfer intended to take effect in possession or enjoyment at or after her death within the meaning…
Also in this document: Concurrence.
2Cases cited23 opinions
- Helvering v. HallockSupreme Court of the United States · 1940
- Knowlton v. MooreSupreme Court of the United States · 1900
- Reinecke v. Northern Trust Co.Supreme Court of the United States · 1929
- Chase National Bank v. United StatesSupreme Court of the United States · 1929
- Tyler v. United StatesSupreme Court of the United States · 1930
18 more not listed; retrieve them via the Exa API.
3Cited by58 opinions
- Fahnestock v. CommissionerUnited States Tax Court · 1945
- Henry v. CommissionerUnited States Tax Court · 1944
- Hall v. CommissionerUnited States Tax Court · 1946
- Campanari v. CommissionerUnited States Tax Court · 1945
- Walker v. CommissionerUnited States Tax Court · 1944
53 more not listed; retrieve them via the Exa API.