Moran v. Commissioner
United States Tax Court
Petitioner's decedent held powers of appointment by will, under two trusts, created prior to the amendment of section 811 of the Internal Revenue Code in 1942. She died in 1947, leaving a will in which she disposed of the property, giving, devising, bequeathing, and appointing it as residuary estate, to her children and their heirs. Her children all survived her and were the same persons who, if surviving her, would have taken in default of appointment.
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Petitioner's decedent held powers of appointment by will, under two trusts, created prior to the amendment of section 811 of the Internal Revenue Code in 1942. She died in 1947, leaving a will in which she disposed of the property, giving, devising, bequeathing, and appointing it as residuary estate, to her children and their heirs. Her children all survived her and were the same persons who, if surviving her, would have taken in default of appointment. She also, in her will, created contingent provisions other than in the trusts which would, had such persons not survived her, have affected…
1Opinion of the Court
Estate of Sarah V. Moran, Deceased, Archibald A. Moran, Executor, Petitioner, v. Commissioner of Internal Revenue, Respondent
Moran v. Commissioner
Docket No. 27701
United States Tax Court
16 T.C. 814; 1951 U.S. Tax Ct. LEXIS 221;
April 19, 1951, Promulgated
Decision will be entered under Rule 50.
Petitioner's decedent held powers of appointment by will, under two trusts, created prior to the amendment of section 811 of the Internal Revenue Code in 1942. She died in 1947, leaving a will in which she disposed of the property, giving, devising, bequeathing, and appointing it as residuary estate, to…
2Cases cited6 opinions
- Helvering v. R. J. Reynolds Tobacco Co.Supreme Court of the United States · 1939
- Estate of Rogers v. CommissionerSupreme Court of the United States · 1943
- Helvering v. GrinnellSupreme Court of the United States · 1935
- Cooper v. HainesCourt of Appeals of Maryland · 1889
- Moran v. CommissionerUnited States Tax Court · 1951
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