Legal Opinion

Estate of Casey v. Commissioner

United States Tax Court

Decided January 13, 1956No. Docket Nos. 54939, 54940PublishedCited by 5 opinions

1Opinion of the Court

OPINION.

Black, Judge:

In computing decedent’s gift tax on the December 13,1951, transfers in trust of Hotel Company and Garage Company stock, petitioners calculated the value of each beneficiary’s right to income from that trust on the basis of the life expectancy of such beneficiary (see Eegs. 108, sec. 86.19 (g), Table A, column 2), and applied the statutory annual exclusion1 to the figure thus arrived at for each beneficiary. Eespondent disallowed the claimed exclusions.

Section 1003 (b) (3) provides that gifts of present interests are ex-cludible to the extent of $3,000 per donee in…

2Cases cited10 opinions

  1. United States v. WellsSupreme Court of the United States · 1931
  2. Allen v. Trust Co. of Ga.Supreme Court of the United States · 1946
  3. Robinette v. HelveringSupreme Court of the United States · 1943
  4. Commissioner of Internal Revenue v. MaresiCourt of Appeals for the Second Circuit · 1946
  5. Evans v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1952

5 more not listed; retrieve them via the Exa API.

3Cited by5 opinions

  1. Estate of Hill v. CommissionerUnited States Tax Court · 1975
  2. Hoover v. United StatesUnited States Court of Claims · 1960
  3. Estate of Schwab v. CommissionerUnited States Tax Court · 1981
  4. Estate of Hill v. CommissionerUnited States Tax Court · 1975
  5. Estate of Talbot v. CommissionerUnited States Tax Court · 1981

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