Legal Opinion

Johnstone v. Commissioner

United States Board of Tax Appeals

Decided February 1, 1934No. Docket No. 66798Published

ESTATE TAX. - Upon the facts it is held that decedent, under two conveyances in trust by him, reserved the right to exercise a control over the ultimate disposition of the trust estates and the value of the trust corpus in each instance is accordingly to be included in his gross estate under section 302(d) of the Revenue Act of 1926. Held, further, in respect to a third trust of which decedent was a beneficiary for life with a general power of disposition of the trust corpus…

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ESTATE TAX. - Upon the facts it is held that decedent, under two conveyances in trust by him, reserved the right to exercise a control over the ultimate disposition of the trust estates and the value of the trust corpus in each instance is accordingly to be included in his gross estate under section 302(d) of the Revenue Act of 1926. Held, further, in respect to a third trust of which decedent was a beneficiary for life with a general power of disposition of the trust corpus by his will, subject, however, to a right of revocation in the donor, that decedent, having exercised by will the power…

1Opinion of the Court

KATE ALLERTON JOHNSTONE, AS EXECUTRIX OF THE ESTATE OF ALLERTON JOHNSTONE, DECEASED, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Johnstone v. Commissioner

Docket No. 66798.

United States Board of Tax Appeals

29 B.T.A. 957; 1934 BTA LEXIS 1447;

February 1, 1934, Promulgated

ESTATE TAX. - Upon the facts it is held that decedent, under two conveyances in trust by him, reserved the right to exercise a control over the ultimate disposition of the trust estates and the value of the trust corpus in each instance is accordingly to be included in his gross estate under section 302(d) of the…

2Cases cited1 opinion

  1. Johnstone v. CommissionerUnited States Board of Tax Appeals · 1934

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