Legal Opinion
Commissioner of Internal Revenue v. Wells
Court of Appeals for the Sixth Circuit
Decided December 1, 1942No. 9103PublishedCited by 22 opinions
1Opinion of the Court
McAllister, circuit judge.
In December, 1935, respondent executed an irrevocable deed of trust to his wife, as trustee, for his two sons. He retained no control over the management, but provided that the amount of income and principal to be distributed to the beneficiaries should rest entirely in the discretion of the trustee. In his gift tax return, respondent deducted two exclusions of $5,000 from the gifts made to his two sons by virtue of the trust — relying upon Sec. 504(b) of the Revenue Act of 1932, 26 U.S.C.A. Int.Rev. Acts, page 585, which provides, in part, that in case of gifts made…
2Cases cited8 opinions
- Hormel v. HelveringSupreme Court of the United States · 1941
- United States v. PelzerSupreme Court of the United States · 1941
- Helvering v. HutchingsSupreme Court of the United States · 1941
- Ryerson v. United StatesSupreme Court of the United States · 1941
- Black Motor Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1942
3 more not listed; retrieve them via the Exa API.
3Cited by22 opinions
- Fondren v. CommissionerSupreme Court of the United States · 1945
- Cloes v. CommissionerUnited States Tax Court · 1982
- United States v. MerrillCourt of Appeals for the Ninth Circuit · 1954
- Irwin S. Chanin v. The United States. Henry I. Chanin v. The United States. Sylvia Chanin v. The United StatesUnited States Court of Claims · 1968
- Stephen F. Heringer, Mabel H. Heringer, John F. Heringer, and Alta G. Heringer v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1956
17 more not listed; retrieve them via the Exa API.