Legal Opinion

Johnson v. Commissioner

United States Board of Tax Appeals

Decided January 31, 1928No. Docket No. 6812Published

Where the decedent, more than two years before her death, transferred, conveyed and delivered real and personal property to her daughter and son, who agreed to pay a stipulated annuity to her for the remainder of her life and to deposit a portion of the property as security for such payments, it is held that the transfer was complete and took effect in possession or enjoyment immediately, and that no part of the property should be included in the decedent's gross estate.

1Opinion of the Court

SEYMOUR JOHNSON AND EDITH SEYMOUR CHISHOLM, EXECUTORS, ESTATE OF SARAH L. JOHNSON, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Johnson v. Commissioner

Docket No. 6812.

United States Board of Tax Appeals

10 B.T.A. 411; 1928 BTA LEXIS 4114;

January 31, 1928, Promulgated

Where the decedent, more than two years before her death, transferred, conveyed and delivered real and personal property to her daughter and son, who agreed to pay a stipulated annuity to her for the remainder of her life and to deposit a portion of the property as security for such payments, it is held that the…

2Cases cited1 opinion

  1. Johnson v. CommissionerUnited States Board of Tax Appeals · 1928

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