Legal Opinion
Fondren v. Commissioner
Supreme Court of the United States
Decided January 29, 1945No. 88PublishedCited by 160 opinions
1Opinion of the CourtJustice Rutledge
In 1935,1936 and 1937 petitioner, Ella F. Fondren, and her husband, since deceased, created seven separate irrevocable trusts, each in favor of a grandchild of tender years; and each of them made gifts to each trust of corporate stock having the fair market value of $5,975. The donors made gift tax returns for 1937, claiming the statutory exclusion of $5,000 for each gift, and accordingly reported taxable gifts for each trust of $975. Gift taxes were paid on this basis.
The Commissioner made deficiency assessments, disallowing the exclusions on the ground that the gifts were of “future…
2Cases cited23 opinions
- United States v. PelzerSupreme Court of the United States · 1941
- Helvering v. HutchingsSupreme Court of the United States · 1941
- Ryerson v. United StatesSupreme Court of the United States · 1941
- Fisher v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1942
- Commissioner of Internal Revenue v. BrandegeeCourt of Appeals for the First Circuit · 1941
18 more not listed; retrieve them via the Exa API.
3Cited by160 opinions
- Trust Under the Will of Bingham v. CommissionerSupreme Court of the United States · 1945
- Mei Xing Yu v. Hasaki Restaurant, Inc.Court of Appeals for the Second Circuit · 2019
- Commissioner v. Estate of HolmesSupreme Court of the United States · 1946
- Commissioner v. DisstonSupreme Court of the United States · 1945
- Weller v. CommissionerUnited States Tax Court · 1962
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