Legal Opinion

Estate of Loughridge v. Commissioner

United States Tax Court

Decided December 6, 1948No. Docket No. 9780Published

1. Estate Tax. -- Held, that the value of the corpus of a trust of which the decedent was grantor is includible in the decedent's gross estate under section 811 (d) (2), Internal Revenue Code, where at the time of his death the decedent as donor had the power to remove the trustee and appoint himself successor trustee and in the latter capacity had the power to terminate the trust, thereby changing the beneficial interest of his minor children from one of future enjoyment to…

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1. Estate Tax. -- Held, that the value of the corpus of a trust of which the decedent was grantor is includible in the decedent's gross estate under section 811 (d) (2), Internal Revenue Code, where at the time of his death the decedent as donor had the power to remove the trustee and appoint himself successor trustee and in the latter capacity had the power to terminate the trust, thereby changing the beneficial interest of his minor children from one of future enjoyment to one of immediate ownership and enjoyment, and also to cut off contingent interests of others. 2. Respondent's…

1Opinion of the Court

Estate of Paul Loughridge, Deceased, Marjorie Mead Loughridge, Executrix, Petitioner, v. Commissioner of Internal Revenue, Respondent

Estate of Loughridge v. Commissioner

Docket No. 9780

United States Tax Court

11 T.C. 968; 1948 U.S. Tax Ct. LEXIS 16;

December 6, 1948, Promulgated

Decision will be entered under Rule 50.

1. Estate Tax. -- Held, that the value of the corpus of a trust of which the decedent was grantor is includible in the decedent's gross estate under section 811 (d) (2), Internal Revenue Code, where at the time of his death the decedent as donor had the power to remove the trustee…

Also in this document: Dissent · Turner; Dissent · Black.

2Cases cited6 opinions

  1. Commissioner v. Estate of HolmesSupreme Court of the United States · 1946
  2. Estate of Budlong v. CommissionerUnited States Tax Court · 1946
  3. Nettleton v. CommissionerUnited States Tax Court · 1945
  4. Hurd v. CommissionerUnited States Tax Court · 1946
  5. Estate of Loughridge v. CommissionerUnited States Tax Court · 1948

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