Legal Opinion
Smith's Estate v. Commissioner of Internal Revenue
Court of Appeals for the Third Circuit
Decided February 2, 1944No. 8444PublishedCited by 11 opinions
1Opinion of the Court
GOODRICH, Circuit Judge.
The Commissioner seeks in this case to sustain his inclusion in the gross estate of Abby R. Smith, who died in 1937, of the value, less a life estate, of certain property conveyed in trust by the decedent in 1919. The trust was made irrevocable in 1925. Alternate grounds are asserted by the Commissioner in support of his action. (1) It is contended that certain future interests, presently to be described, are in violation of the Pennsylvania rule against perpetuities and therefore the value of those interests is includible in the gross estate under § 302(a) of the…
2Cases cited16 opinions
- Helvering v. HallockSupreme Court of the United States · 1940
- Commissioner v. HeiningerSupreme Court of the United States · 1943
- Dobson v. CommissionerSupreme Court of the United States · 1944
- Estate of Rogers v. CommissionerSupreme Court of the United States · 1943
- Appeal of CogginsSupreme Court of Pennsylvania · 1889
11 more not listed; retrieve them via the Exa API.
3Cited by11 opinions
- Helvering v. StormfeltzCourt of Appeals for the Eighth Circuit · 1944
- Sellers v. PowersTexas Supreme Court · 1968
- Para Pierce Aldrich v. United StatesCourt of Appeals for the Fifth Circuit · 1965
- Estate of Ellen M. Wien, Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1971
- Carpenter v. United StatesUnited States Court of Claims · 1984
6 more not listed; retrieve them via the Exa API.