Legal Opinion

Jardell v. Commissioner

United States Tax Court

Decided July 14, 1955No. Docket No. 48489Published

Gifts on October 2, 1949, of shares in "royalty interest owned and to be paid or delivered to donor from the production of * * * minerals" but to become effective only as to production commencing January 1, 1950, held to consist of future interests precluding allowance of exclusions.

1Opinion of the Court

Estate of Louise Jardell, Deceased, Alec John Jardell, Administrator, Petitioner, v. Commissioner of Internal Revenue, Respondent

Jardell v. Commissioner

Docket No. 48489

United States Tax Court

24 T.C. 652; 1955 U.S. Tax Ct. LEXIS 140; 4 Oil & Gas Rep. 2049;

July 14, 1955, Filed

Decision will be entered for the respondent.

Gifts on October 2, 1949, of shares in "royalty interest owned and to be paid or delivered to donor from the production of * * * minerals" but to become effective only as to production commencing January 1, 1950, held to consist of future interests precluding allowance of…

2Cases cited3 opinions

  1. Fondren v. CommissionerSupreme Court of the United States · 1945
  2. Hessenbruch v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1950
  3. Jardell v. CommissionerUnited States Tax Court · 1955

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