Michel v. Commissioner
United States Board of Tax Appeals
1. A transfer in trust reserving the reversion if the settlor survives the beneficiary is not subject to gift tax. 2. A motion to reopen for further evidence "bearing upon the discount factors if any" applicable to the values of the transferred property "by reason of the reservation of possibilities of reverter", and a stipulation of factors of computation, held, not sufficient for decision as to the existence or value of a gift of other than the property, no such issue…
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1. A transfer in trust reserving the reversion if the settlor survives the beneficiary is not subject to gift tax. 2. A motion to reopen for further evidence "bearing upon the discount factors if any" applicable to the values of the transferred property "by reason of the reservation of possibilities of reverter", and a stipulation of factors of computation, held, not sufficient for decision as to the existence or value of a gift of other than the property, no such issue being raised by the pleadings.
1Opinion of the Court
COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Michel v. Commissioner
Docket Nos. 97311, 97312.
United States Board of Tax Appeals
43 B.T.A. 1036; 1941 BTA LEXIS 1420;
March 19, 1941, Promulgated
1. A transfer in trust reserving the reversion if the settlor survives the beneficiary is not subject to gift tax.
2. A motion to reopen for further evidence "bearing upon the discount factors if any" applicable to the values of the transferred property "by reason of the reservation of possibilities of reverter", and a stipulation of factors of computation, held,…
2Cases cited1 opinion
- Michel v. CommissionerUnited States Board of Tax Appeals · 1941