McCoach v. Pratt
Supreme Court of the United States
CERTIORARI TO THE CIRCUIT COURT OF APPEALS FOR THE THIRD CIRCUIT. The facts, which involve the construction of the War Revenue Act of 1898 and the refunding act of June 27, 1902, are stated in the opinion. Taxability of the direct bequests depends on taxability of the annuities to the grandchildren. They are taxable under § 29, act of 1898. Legacy includes annuity and there is no legal difference between it and life estate in income.
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CERTIORARI TO THE CIRCUIT COURT OF APPEALS FOR THE THIRD CIRCUIT. The facts, which involve the construction of the War Revenue Act of 1898 and the refunding act of June 27, 1902, are stated in the opinion. Taxability of the direct bequests depends on taxability of the annuities to the grandchildren. They are taxable under § 29, act of 1898. Legacy includes annuity and there is no legal difference between it and life estate in income. Whether the estate is vested or contingent, and however it is called, it is taxable because not conditional. United States v. Fidelity Trust Co., 222 U. S. 159;…
1Opinion of the CourtJustice Van Devanter
Whether a succession tax collected under §§ 29 and 30 of the act of June 13, 1898, c. 448, 30 Stat. 448, 464, shall be refunded is the matter here in controversy. The facts bearing upon its solution are these: Ferdinand J. Dreer, a resident of Philadelphia, Pennsylvania, died May 24, 1902, leaving a will directing that certain legacies be paid out of his personal estate to two sons and two grandchildren. The executors took charge of the property and proceeded to administer it under the supervision of the Orphans’ Court, as the local law required, first for the benefit of the creditors and…
2Cases cited3 opinions
- Hertz v. WoodmanSupreme Court of the United States · 1910
- Vanderbilt v. EidmanSupreme Court of the United States · 1905
- United States v. Fidelity Trust Co.Supreme Court of the United States · 1911
3Cited by13 opinions
- Sage v. United StatesSupreme Court of the United States · 1919
- Simpson v. United StatesSupreme Court of the United States · 1920
- Uterhart v. United StatesSupreme Court of the United States · 1916
- Henry v. United StatesSupreme Court of the United States · 1920
- Kahn v. United StatesSupreme Court of the United States · 1921
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