Legal Opinion

Chrysler v. Commissioner

United States Tax Court

Decided April 7, 1965No. Docket No. 1322-63PublishedCited by 27 opinions

Held: (1) The values of the corpora of two irrevocable trusts created by decedent on June 16, 1945, and December 6, 1946, are not includable in decedent's gross estate under the provisions of section 2036(a), I.R.C. 1954; (2) the values of certain properties held jointly by decedent and others at his death are includable in decedent's gross estate under the provisions of section 2040, I.R.C. 1954; and (3) the values of certain properties transferred by decedent to himself as…

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Held: (1) The values of the corpora of two irrevocable trusts created by decedent on June 16, 1945, and December 6, 1946, are not includable in decedent's gross estate under the provisions of section 2036(a), I.R.C. 1954; (2) the values of certain properties held jointly by decedent and others at his death are includable in decedent's gross estate under the provisions of section 2040, I.R.C. 1954; and (3) the values of certain properties transferred by decedent to himself as custodian for his minor children are includable in his gross estate under the provisions of sections 2036(a) and…

1Opinion of the Court

Akundell, Judge:

Respondent determined a deficiency in estate tax of $1,023,714.51.

Respondent included in decedent’s gross estate certain transfers made during decedent’s life in the total amount of $1,601,875.19 made up of the following items:

Item 2- $534, 920.37

Item 3-,_ 698,120. 83

Item 4- 28, 537. 66

Item 5-1_• 28, 067. 54

Item 7 (items 11 through 37)_ 155,615.25

Item 8 (items 38 through 65)_ 156, 613. 54

Total transfers included in gross estate_ 1, 601, 875.19

The parties have stipulated that the value of item 7 at the date of decedent’s death was $156,251.16 instead of $155,615.25, and that…

2Cases cited17 opinions

  1. Commissioner v. Estate of HolmesSupreme Court of the United States · 1946
  2. Lober v. United StatesSupreme Court of the United States · 1953
  3. King v. CommissionerUnited States Tax Court · 1962
  4. Helvering v. Mercantile-Commerce Bank & Trust Co.Court of Appeals for the Eighth Circuit · 1940
  5. Commission of Internal Revenue v. Dwight's EstateCourt of Appeals for the Second Circuit · 1953

12 more not listed; retrieve them via the Exa API.

3Cited by27 opinions

  1. Varian v. CommissionerUnited States Tax Court · 1966
  2. Stuit v. CommissionerUnited States Tax Court · 1970
  3. Schwartz EstateSupreme Court of Pennsylvania · 1972
  4. Estate of Prudowsky v. CommissionerUnited States Tax Court · 1971
  5. Anastasio v. CommissionerUnited States Tax Court · 1977

22 more not listed; retrieve them via the Exa API.

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