Legal Opinion
Jewett v. Commissioner
Supreme Court of the United States
Decided February 23, 1982No. 80-1614PublishedCited by 108 opinions
1Opinion of the CourtJustice Stevens
A trust beneficiary’s refusal to accept ownership of property may constitute an indirect gift to a successor in interest subject to federal gift tax liability. 26 U. S. C. §§2501, 2511. Under Treasury Regulation §25.2511-l(c), however, such a refusal is not subject to tax if it is effective under local law and made “within a reasonable time after knowledge of the existence of the transfer.” The petitioner husband (hereafter petitioner) in this case executed disclaimers of a contingent interest in a testamentary trust 33 years after that interest was created, but while it was still contingent.…
2Cases cited10 opinions
- Helvering v. HallockSupreme Court of the United States · 1940
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Estate of Sanford v. CommissionerSupreme Court of the United States · 1939
- Commissioner v. Portland Cement Co. of UtahSupreme Court of the United States · 1981
- Smith v. ShaughnessySupreme Court of the United States · 1943
5 more not listed; retrieve them via the Exa API.
3Cited by108 opinions
- Drye v. United StatesSupreme Court of the United States · 2000
- Williams v. ElyMassachusetts Supreme Judicial Court · 1996
- Elizabeth N. Callaway v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 2000
- David Dewees and Anne Dewees v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1989
- United States v. IrvineSupreme Court of the United States · 1994
103 more not listed; retrieve them via the Exa API.