Bradley v. Commissioner
United States Tax Court
1. In 1918 decedent executed an irrevocable trust under which his daughter was to receive $ 1,000 of the income per annum during her lifetime, with the balance of the income to be paid to his wife during life. In the event the wife predeceased the daughter, leaving decedent surviving, the balance of the income was to be paid to the decedent, his executors, administrators and assigns, during the life of the daughter.
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1. In 1918 decedent executed an irrevocable trust under which his daughter was to receive $ 1,000 of the income per annum during her lifetime, with the balance of the income to be paid to his wife during life. In the event the wife predeceased the daughter, leaving decedent surviving, the balance of the income was to be paid to the decedent, his executors, administrators and assigns, during the life of the daughter. Upon the death of the daughter without issue, the remainder was to be paid to the residuary legatees named in the wife's will. The wife died in 1929, leaving a last will and…
1Opinion of the Court
OPINION.
Leech, Judge:
This proceeding involves a deficiency in estate tax in the amount of $231,756.27. The sole contested issue is whether the corpora of two trusts are includible in decedent’s gross estate as trusts intended to take effect in possession or enjoyment at or after decedent’s death, within the provisions of section 302 (c) of the Eevenue Act of 1926, as amended. All the facts have been stipulated and are so found. They may be summarized for present purposes as follows:
Petitioner, Julie F. Fremont, is the executrix of the last will and testament of Edson Bradley, deceased, who…
2Cases cited11 opinions
- Helvering v. HallockSupreme Court of the United States · 1940
- Blair v. CommissionerSupreme Court of the United States · 1937
- Lyeth v. HoeySupreme Court of the United States · 1938
- Freuler v. HelveringSupreme Court of the United States · 1934
- May v. HeinerSupreme Court of the United States · 1930
6 more not listed; retrieve them via the Exa API.
3Cited by5 opinions
- Arents v. CommissionerUnited States Tax Court · 1960
- Equitable Savings & Loan Ass'n v. State Tax CommissionOregon Supreme Court · 1968
- Equitable Savings & Loan Ass'n v. State Tax CommissionOregon Tax Court · 1967
- Arents v. CommissionerUnited States Tax Court · 1960
- Bradley v. CommissionerUnited States Tax Court · 1947