Tidemann v. Commissioner
United States Tax Court
1. In 1935 petitioners created five irrevocable trusts for the benefit of their five children and upon certain conditions their grandchildren. The trusts were to terminate in 1955, but could be extended by "the Grantor, with the consent of the Trustee hereunder, until such date as he may designate." Petitioners reserved no power to change the beneficiaries or to change the portions any beneficiary would receive.
Read the full summary
1. In 1935 petitioners created five irrevocable trusts for the benefit of their five children and upon certain conditions their grandchildren. The trusts were to terminate in 1955, but could be extended by "the Grantor, with the consent of the Trustee hereunder, until such date as he may designate." Petitioners reserved no power to change the beneficiaries or to change the portions any beneficiary would receive. Only upon a failure to take by any one or more of the several beneficiaries in the five trusts would there be any possibility of reverter in the grantors. Held, petitioners made…
1Opinion of the Court
OPINION.
Black, Judge:
In these proceedings, which have been consolidated, the respondent has determined a deficiency of $795.27 in gift tax for the year 19B6 against each petitioner.
On March 17, 1941, the Board entered a memorandum opinion in these proceedings disposing of the issues then raised by the pleadings. Subsequent thereto and before entering any decision on motion of the respondent filed April 1, 1941, “to vacate and set aside report, for rehearing, and for leave to file amended answers” claiming that each deficiency be increased to $1,924.28, the Board on June 11, 1941, granted…
2Cases cited13 opinions
- Helvering v. HallockSupreme Court of the United States · 1940
- Estate of Sanford v. CommissionerSupreme Court of the United States · 1939
- United States v. PelzerSupreme Court of the United States · 1941
- Porter v. CommissionerSupreme Court of the United States · 1933
- United States v. RyersonSupreme Court of the United States · 1941
8 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Allen v. CommissionerUnited States Tax Court · 1944
- Goldstein v. CommissionerUnited States Tax Court · 1962
- Allen v. CommissionerUnited States Tax Court · 1944
- Frank v. CommissionerUnited States Tax Court · 1944
- Goldstein v. CommissionerUnited States Tax Court · 1962
2 more not listed; retrieve them via the Exa API.