City Bank Farmers Trust Co. v. Commissioner
United States Board of Tax Appeals
The decedent on February 21, 1930, conveyed certain property in trust, reserving to herself the income for life. The trust was revocable only with the consent of her husband, who was a beneficiary. Held, that the property conveyed in trust is not includable in her gross estate.
1Opinion of the Court
*1142OPINION.
Smith :
This proceeding involves a deficiency in the estate tax of Gertrude Feldman James, deceased, in the amount of $11,840.03. The only question at issue is whether the value of certain securities which the petitioner conveyed in trust prior to her decease was a part of her gross estate for estate tax purposes.
The essential facts have been stipulated. The decedent died a nonresident of the United States on May 20, 1931. Prior to her death and by a certain agreement hearing date of February 21, 1930, she transferred certain securities, consisting principally of stocks and bonds, to…
2Cases cited5 opinions
- Reinecke v. Northern Trust Co.Supreme Court of the United States · 1929
- Stetson v. CommissionerUnited States Board of Tax Appeals · 1932
- Lit v. CommissionerUnited States Board of Tax Appeals · 1933
- Holmes v. CommissionerUnited States Board of Tax Appeals · 1933
- Stone v. CommissionerUnited States Board of Tax Appeals · 1932
3Cited by3 opinions
- Peppiatt v. CommissionerUnited States Tax Court · 1978
- City Bank Farmers Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Peppiatt v. CommissionerUnited States Tax Court · 1978