Quatman v. Commissioner
United States Tax Court
Petitioner transferred farm property in trust to pay the net income to his four children until the youngest reached 21 years of age at which time the corpus of the trust was to be paid over to them. Held, the gifts of corpus were gifts of future interests in property. Held, further, the gifts of the right to receive the net income from the property were present interests, the value of which could be determined under sec. 25.2512-5, Gift Tax Regs.
1Opinion of the Court
OPINION
Quealy, Judge:
The Commissioner determined a deficiency of
$1,839.60 in the Federal gift tax of Frank T. Quatman for the calendar year 1964.
The issue presented for decision is whether a gift made by petitioner Frank T. Quatman in trust for the benefit of his four children was a gift of a future interest.
The facts have been stipulated. The stipulation of facts and exhibits thereto are incorporated herein by this reference.
At the time his petition was filed, petitioner was a legal resident of Lima, Ohio. He filed his Federal gift tax return for 1964 with the district director of internal…
2Cases cited23 opinions
- Fondren v. CommissionerSupreme Court of the United States · 1945
- Commissioner v. DisstonSupreme Court of the United States · 1945
- Arnold Van Den Wymelenberg, as of the Estate of Eleanor Van Den Wymelenberg, and Arnold Van Den Wymelenberg v. United StatesCourt of Appeals for the Seventh Circuit · 1968
- Fisher v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1942
- Irwin S. Chanin v. The United States. Henry I. Chanin v. The United States. Sylvia Chanin v. The United StatesUnited States Court of Claims · 1968
18 more not listed; retrieve them via the Exa API.
3Cited by12 opinions
- Estate of Cristofani v. CommissionerUnited States Tax Court · 1991
- Blasdel v. CommissionerUnited States Tax Court · 1972
- Estate of Kolker v. CommissionerUnited States Tax Court · 1983
- Swetland v. CommissionerUnited States Tax Court · 1978
- Clark v. CommissionerUnited States Tax Court · 1975
7 more not listed; retrieve them via the Exa API.