Gramm v. Commissioner
United States Tax Court
Decedent created a trust with income to herself for life. The trustees were a corporate trustee and decedent's two children. The corporate trustee had the power to invade the corpus for the comfort, education, maintenance, or support of decedent. The respondent determined the transfer in trust was subject to a gift tax.
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Decedent created a trust with income to herself for life. The trustees were a corporate trustee and decedent's two children. The corporate trustee had the power to invade the corpus for the comfort, education, maintenance, or support of decedent. The respondent determined the transfer in trust was subject to a gift tax. Held, no complete taxable transfer was effected by the deed of trust since the corpus might have been totally depleted by the time of decedent's death without the consent of any adverse party.
1Opinion of the Court
Estate of Christianna K. Gramm, Deceased, Theodore K. Gramm and Ida G. Betelle, Executors, Petitioners, v. Commissioner of Internal Revenue, Respondent
Gramm v. Commissioner
Docket No. 27511
United States Tax Court
17 T.C. 1063; 1951 U.S. Tax Ct. LEXIS 4;
December 28, 1951, Promulgated
Decision will be entered under Rule 50.
Decedent created a trust with income to herself for life. The trustees were a corporate trustee and decedent's two children. The corporate trustee had the power to invade the corpus for the comfort, education, maintenance, or support of decedent. The respondent determined the…
2Cases cited12 opinions
- Estate of Sanford v. CommissionerSupreme Court of the United States · 1939
- Merchants Nat. Bank of Boston v. CommissionerSupreme Court of the United States · 1943
- Herzog v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1941
- Toeller v. CommissionerUnited States Tax Court · 1946
- Blunt v. KellyCourt of Appeals for the Third Circuit · 1942
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