Legal Opinion
Commissioner of Internal Revenue v. Singer's Estate
Court of Appeals for the Second Circuit
Decided April 15, 1947No. 173, Docket 20448PublishedCited by 7 opinions
1Opinion of the Court
CLARK, Circuit Judge.
The sol.e question presented is whether or not an estate tax is collectible upon the principal of an inter vivos trust because the settlor retained a remote contingent power of appointment by deed among members of a restricted class. Two trusts are in suit, both created by the decedent in 1891 as part of an antenuptial agreement with his first wife, Blanche. Upon the decedent’s death in 1939, the Commissioner of Internal Revenue determined a deficiency of $508,985.71 in estate tax by including the principal of the trusts in the decedent’s gross estate. But the Tax Court…
2Cases cited31 opinions
- Helvering v. HallockSupreme Court of the United States · 1940
- Dobson v. CommissionerSupreme Court of the United States · 1944
- Hassett v. WelchSupreme Court of the United States · 1938
- May v. HeinerSupreme Court of the United States · 1930
- Commissioner v. WilcoxSupreme Court of the United States · 1946
26 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Barnett Hollander, of the Will of Lester Field, Deceased v. United StatesCourt of Appeals for the Second Circuit · 1957
- Graham v. CommissionerUnited States Tax Court · 1966
- James W. Costin, of the Estate of Earl M. Costin, Deceased v. Ralph W. Cripe, Collector of Internal RevenueCourt of Appeals for the Seventh Circuit · 1956
- Barnett Hollander, of the Will of Lester Field, Deceased v. United StatesCourt of Appeals for the Second Circuit · 1957
- Commissioner v. Estate of ChurchSupreme Court of the United States · 1949
2 more not listed; retrieve them via the Exa API.