Aaron v. Commissioner
United States Tax Court
Estate Tax -- Contemplation of Death -- Funded Life Insurance Trust -- Sec. 811 (c) (1) (A), I. R. C. -- The value of bonds and life insurance policies transferred to trusts is includible in the decedent's gross estate as transfers made in contemplation of death where the trusts would not provide any economic or other benefit to the beneficiaries until the death of the decedent and the transfers were not made for motives associated with life.
1Opinion of the Court
OPINION.
Muedock, Judge:
The Commissioner does not argue that the condition of the health of the decedent in any way prompted the 1931 transfers, and clearly it did not. The justification for the determination that those transfers were made in contemplation of death must be found in the use and the terms of the trusts, the nature and possibilities of the property transferred, and the intent of the settlor shown by that and all other evidence in the record. The decedent was keen and intelligent. He knew what could be expected of the trusts. He knew that the income from, the securities which the…
2Cases cited14 opinions
- Vanderlip v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1946
- Vanderlip v. CommissionerUnited States Tax Court · 1944
- Cronin v. CommissionerUnited States Tax Court · 1946
- Garrett's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1950
- Ruthrauff v. CommissionerUnited States Tax Court · 1947
9 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Aaron v. CommissionerUnited States Tax Court · 1953