Palmer v. Commissioner
United States Board of Tax Appeals
1. Held, that by the execution of a trust agreement the petitioner, as grantor, irrevocably conveyed in praesenti his legal title to certain stock to the trust thereby created and irrevocably conveyed in praesenti the beneficial interest to his wife for life, with remainder interests to his children and their issue. 2. Held, that the execution of the trust agreement effectively passed title to petitioner, as trustee, without manual delivery and despite the fact that the…
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1. Held, that by the execution of a trust agreement the petitioner, as grantor, irrevocably conveyed in praesenti his legal title to certain stock to the trust thereby created and irrevocably conveyed in praesenti the beneficial interest to his wife for life, with remainder interests to his children and their issue. 2. Held, that the execution of the trust agreement effectively passed title to petitioner, as trustee, without manual delivery and despite the fact that the stock transferred in trust remained registered in the petitioner's name and pledged as collateral security for certain…
1Opinion of the Court
*1006OPINION.
Tyson :
The issue presented is whether the petitioner is taxable upon the $25,503 dividends declared and paid during the period May 26 to December 31, 1932, upon the shares of E. R. Squibb & *1007Sons stock which were the subject matter of the trust agreement of May 26,1932, as set forth in our findings of fact.
The respondent determined, and now contends, that the execution of the trust agreement of May 26, 1932, was ineffectual; that there was no complete, irrevocable conveyance of the stock to the trust in praesenti/ that the petitioner retained and continued to exercise throughout 1932…
2Cases cited7 opinions
- Reinecke v. Northern Trust Co.Supreme Court of the United States · 1929
- Gillet v. . Bank of AmericaNew York Court of Appeals · 1899
- Robb v. . Washington Jefferson CollegeNew York Court of Appeals · 1906
- US Trust Co. v. Commissioner of Internal RevenueSupreme Court of the United States · 1936
- In Re the Accounting of BrownNew York Court of Appeals · 1930
2 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Palmer v. CommissionerUnited States Board of Tax Appeals · 1939