Ruxton v. Commissioner
United States Tax Court
1. Estate Tax -- Reciprocal or Crossed Trusts. -- Where the facts and circumstances surrounding the creation of trusts by the decedent and her husband on the same date show that they were not interdependent or in consideration of each other and lacked a quid pro quo of substantially the same degree of beneficial right or control, held, that the reciprocal or crossed trust doctrine is not applicable. 2. Id. -- Deduction. -- Allowed in amount of reasonable estimate of fee for…
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1. Estate Tax -- Reciprocal or Crossed Trusts. -- Where the facts and circumstances surrounding the creation of trusts by the decedent and her husband on the same date show that they were not interdependent or in consideration of each other and lacked a quid pro quo of substantially the same degree of beneficial right or control, held, that the reciprocal or crossed trust doctrine is not applicable. 2. Id. -- Deduction. -- Allowed in amount of reasonable estimate of fee for services of special guardian which will be paid prior to the executor's final accounting.
1Opinion of the Court
Estate of Louise DeWitt Ruxton, Deceased, by Guaranty Trust Company et al., Executors, Petitioner, v. Commissioner of Internal Revenue, Respondent
Ruxton v. Commissioner
Docket No. 35682
United States Tax Court
20 T.C. 487; 1953 U.S. Tax Ct. LEXIS 139;
May 28, 1953, Promulgated
Decision will be entered under Rule 50.
1. Estate Tax -- Reciprocal or Crossed Trusts. -- Where the facts and circumstances surrounding the creation of trusts by the decedent and her husband on the same date show that they were not interdependent or in consideration of each other and lacked a quid pro quo of substantially the…
2Cases cited8 opinions
- Orvis v. HigginsCourt of Appeals for the Second Circuit · 1950
- Lehman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1940
- Cole's Estate v. Com'r of Internal RevenueCourt of Appeals for the Eighth Circuit · 1944
- Hanauer's Estate v. Commissioner of Internal Rev.Court of Appeals for the Second Circuit · 1945
- In Re Lueders'estateCourt of Appeals for the Third Circuit · 1947
3 more not listed; retrieve them via the Exa API.