Thacher v. Commissioner
United States Tax Court
1. Held, on the record that six conveyances of property to six trusts for the benefit of settlor's five minor children and wife were not made in contemplation of death within section 811 (c), Internal Revenue Code. 2. In the instrument creating the trust for the benefit of the wife, decedent retained a specific reversion that in case of divorce or legal separation, or in case his wife predeceased him, the corpus of the trust was to be paid over to him by the trustee.
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1. Held, on the record that six conveyances of property to six trusts for the benefit of settlor's five minor children and wife were not made in contemplation of death within section 811 (c), Internal Revenue Code. 2. In the instrument creating the trust for the benefit of the wife, decedent retained a specific reversion that in case of divorce or legal separation, or in case his wife predeceased him, the corpus of the trust was to be paid over to him by the trustee. Held: a. The wife's life interest terminable only by her predeceasing the decedent was not an interest intended to take effect…
1Opinion of the Court
Estate of Frank W. Thacher, Deceased, Provident Trust Company of Philadelphia, Catharine L. Thacher, Franklin William Thacher, Jr., and John Hoover Thacher, Executors, Petitioners, v. Commissioner of Internal Revenue, Respondent
Thacher v. Commissioner
Docket No. 17382
United States Tax Court
20 T.C. 474; 1953 U.S. Tax Ct. LEXIS 137;
May 28, 1953, Promulgated
Decision will be entered under Rule 50.
1. Held, on the record that six conveyances of property to six trusts for the benefit of settlor's five minor children and wife were not made in contemplation of death within section 811 (c), Internal…
2Cases cited19 opinions
- Helvering v. HallockSupreme Court of the United States · 1940
- United States v. WellsSupreme Court of the United States · 1931
- Commissioner of Internal Revenue v. MaresiCourt of Appeals for the Second Circuit · 1946
- First-Mechanics Nat. Bank v. Commissioner of Int. Rev.Court of Appeals for the Third Circuit · 1940
- Estate of Maresi v. CommissionerUnited States Tax Court · 1946
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