Legal Opinion

Fidelity-Philadelphia Trust Co. v. Commissioner

United States Board of Tax Appeals

Decided March 20, 1933No. Docket No. 51334Published

In December 1918, decedent created two trusts for the benefit of his two daughters, providing that the income therefrom should be paid to them during their lives, and, upon their respective deaths, the principal or corpus of each trust should be paid over to the decedent, if living, or if he were not living, then to such person or persons as the decedent might by his will direct, limit and appoint.

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In December 1918, decedent created two trusts for the benefit of his two daughters, providing that the income therefrom should be paid to them during their lives, and, upon their respective deaths, the principal or corpus of each trust should be paid over to the decedent, if living, or if he were not living, then to such person or persons as the decedent might by his will direct, limit and appoint. Decedent died in January 1928. Held, the value at decedent's death of the corpus of the trusts is taxable as a part of decedent's gross estate. Klein v. United States,283 U.S. 231.

1Opinion of the Court

FIDELITY-PHILADELPHIA TRUST COMPANY, LOUISE REACH AND GEORGE A. REACH, EXECUTORS, ESTATE OF ALFRED J. REACH, DECEASED, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Fidelity-Philadelphia Trust Co. v. Commissioner

Docket No. 51334.

United States Board of Tax Appeals

27 B.T.A. 972; 1933 BTA LEXIS 1272;

March 20, 1933, Promulgated

In December 1918, decedent created two trusts for the benefit of his two daughters, providing that the income therefrom should be paid to them during their lives, and, upon their respective deaths, the principal or corpus of each trust should be paid over to…

2Cases cited2 opinions

  1. Klein v. United StatesSupreme Court of the United States · 1931
  2. Fidelity-Philadelphia Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1933

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