Legal Opinion

American Nat'l Bank & Trust Co. v. Commissioner

United States Tax Court

Decided October 3, 1974No. Docket Nos. 2854-72, 2855-72, 2901-72Unpublished

Held, the value of the assets in a trust established in 1955 in decedent's name and with decedent as the named grantor, under the terms of which decedent reserved unto herself the income for life, is taxable in decedent's estate despite petitioners' claim that the assets transferred to the trust really belonged to decedent's husband and that he was the real grantor of the trust.

1Opinion of the Court

AMERICAN NATIONAL BANK & TRUST CO., ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

American Nat'l Bank & Trust Co. v. Commissioner

Docket Nos. 2854-72, 2855-72, 2901-72.

United States Tax Court

T.C. Memo 1974-263; 1974 Tax Ct. Memo LEXIS 56; 33 T.C.M. (CCH) 1158; T.C.M. (RIA) 740263;

October 3, 1974, Filed.

Held, the value of the assets in a trust established in 1955 in decedent's name and with decedent as the named grantor, under the terms of which decedent reserved unto herself the income for life, is taxable in decedent's estate despite petitioners' claim that the assets…

2Cases cited16 opinions

  1. Aquilino v. United StatesSupreme Court of the United States · 1960
  2. Morgan v. CommissionerSupreme Court of the United States · 1940
  3. Burnet v. Commonwealth Improvement Co.Supreme Court of the United States · 1932
  4. Commissioner v. DanielsonCourt of Appeals for the Third Circuit · 1967
  5. Danielson v. CommissionerUnited States Tax Court · 1965

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