Legal Opinion
Estate of Lindsay v. Commissioner
United States Tax Court
Decided June 22, 1943No. Docket Nos. 109981, 109982PublishedCited by 16 opinions
1Opinion of the Court
OPINION.
Van Fossan, Judge:
The notices of deficiency give no hint of respondent’s theory in adding the trust corpus to the taxable estate of the life income beneficiary. The statement in the case of Samual S. Lindsay was as follows: “The transfer by Helen P. Lindsay on December 28, 1934, is considered to form a part of the decedent’s gross estate under section 302 of the Revenue Act of 1926, as amended.” The statement in the companion case is identical except for change of name.
At the hearing respondent’s counsel shied away from the suggestion that the determination was based on the theory…
2Cases cited1 opinion
- Helvering v. CliffordSupreme Court of the United States · 1940
3Cited by16 opinions
- Estate of Bischoff v. CommissionerUnited States Tax Court · 1977
- Hanauer's Estate v. Commissioner of Internal Rev.Court of Appeals for the Second Circuit · 1945
- Newberry v. CommissionerUnited States Tax Court · 1951
- Estate of Eckhardt v. CommissionerUnited States Tax Court · 1945
- Newberry's Estate v. Commissioner of Internal Revenue. Commissioner of Internal Revenue v. Newberry's Estate John J. Newberry Trust No. 1 v. Commissioner of Internal Revenue (Two Cases)Court of Appeals for the Third Circuit · 1953
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