Legal Opinion

Frazer v. Commissioner

United States Tax Court

Decided May 31, 1946No. Docket No. 6682Published

The will of Robert S. Frazer, father of decedent, created two trusts, terminating upon the death of the life beneficiaries. The trust remainders were to fall into the testator's residuary estate. Decedent was one of three residuary legatees under said will. Held, the value of a one-third interest in the trust remainders was taxable as part of the decedent's gross estate under section 811 (a), I. R. C.

1Opinion of the Court

Estate of John G. Frazer, Deceased, Katharine Reed Frazer, Executrix, Petitioner, v. Commissioner of Internal Revenue, Respondent

Frazer v. Commissioner

Docket No. 6682

United States Tax Court

6 T.C. 1255; 1946 U.S. Tax Ct. LEXIS 171;

May 31, 1946, Promulgated

Decision will be entered under Rule 50.

The will of Robert S. Frazer, father of decedent, created two trusts, terminating upon the death of the life beneficiaries. The trust remainders were to fall into the testator's residuary estate. Decedent was one of three residuary legatees under said will. Held, the value of a one-third interest in the…

2Cases cited5 opinions

  1. In Re the Judicial Settlement of the Accounts of JamesNew York Court of Appeals · 1895
  2. Allen v. HirlingerSupreme Court of Pennsylvania · 1907
  3. Raleigh's EstateSupreme Court of Pennsylvania · 1903
  4. Scott's EstateSupreme Court of Pennsylvania · 1933
  5. Frazer v. CommissionerUnited States Tax Court · 1946

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