Estate of Dillingham v. Commissioner
United States Tax Court
The decedent delivered checks in the amount of $ 3,000 each to six different individual donees in 1980. In 1981, the donees presented the checks to the drawee bank for payment and the checks were paid.
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The decedent delivered checks in the amount of $ 3,000 each to six different individual donees in 1980. In 1981, the donees presented the checks to the drawee bank for payment and the checks were paid. Held, the payment of the checks in 1981 did not relate back to the delivery of the checks in 1980 for purposes of determining when the gifts were complete under secs. 2501 and 2511, I.R.C. 1954, because petitioner failed to prove unconditional delivery of the checks to the donees. Held, further, the decedent did not part with "dominion and control" over the property which was the subject of the…
1Opinion of the Court
Estate of Elizabeth C. Dillingham, Deceased, Dan L. Dillingham and Tom B. Dillingham, Coexecutors, Petitioner v. Commissioner of Internal Revenue, Respondent
Estate of Dillingham v. Commissioner
Docket Nos. 22368-85, 22369-85
United States Tax Court
88 T.C. 1569; 1987 U.S. Tax Ct. LEXIS 89; 88 T.C. No. 89;
June 25, 1987. June 25, 1987, Filed
Decisions will be entered under Rule 155.
The decedent delivered checks in the amount of $ 3,000 each to six different individual donees in 1980. In 1981, the donees presented the checks to the drawee bank for payment and the checks were paid. Held, the payment…
2Cases cited12 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Commissioner v. Estate of BoschSupreme Court of the United States · 1967
- Burnet v. HarmelSupreme Court of the United States · 1932
- Don E. Williams Co. v. CommissionerSupreme Court of the United States · 1977
- Spiegel v. CommissionerUnited States Tax Court · 1949
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