Legal Opinion

First Trust & Deposit Co. v. Commissioner

United States Board of Tax Appeals

Decided January 19, 1940No. Docket Nos. 90749, 90750, 90751Published

Petitioners' wards were remaindermen of a trust created in 1926 in the State of New York, where it was administered. The trust provided that, upon the death of the survivor of two life beneficiaries, the inheritance taxes against the estate of the settlor should be paid out of corpus and that the corpus, together with any accumulations thereon, be paid over to petitioners' wards in equal parts.

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Petitioners' wards were remaindermen of a trust created in 1926 in the State of New York, where it was administered. The trust provided that, upon the death of the survivor of two life beneficiaries, the inheritance taxes against the estate of the settlor should be paid out of corpus and that the corpus, together with any accumulations thereon, be paid over to petitioners' wards in equal parts. The life beneficiaries died simultaneously in 1929. The inheritance taxes were not all determined nor paid until August 1934. In May 1935, the trust instituted action for judicial settlement of its…

1Opinion of the Court

FIRST TRUST & DEPOSIT COMPANY AND GWYNN W. HOYT, AS GUARDIANS OF THE PROPERTY OF WILLARD C. LIPE, JR., PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

FIRST TRUST & DEPOSIT COMPANY AND GWYNN W. HOYT, AS GUARDIANS OF THE PROPERTY OF GORDON C. LIPE, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

FIRST TRUST & DEPOSIT COMPANY AND GWYNN W. HOYT, AS GUARDIANS OF THE PROPERTY OF SUZANNE H. LIPE, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

First Trust & Deposit Co. v. Commissioner

Docket Nos. 90749, 90750, 90751.

United States Board of Tax Appeals

41 B.T.A.…

2Cases cited1 opinion

  1. First Trust & Deposit Co. v. CommissionerUnited States Board of Tax Appeals · 1940

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