Legal Opinion

Estate of Mandels v. Commissioner

United States Tax Court

Decided April 17, 1975No. Docket Nos. 4848-70, 6903-70, 8520-72, 8530-72Published

In 1962, decedent created a trust in which he reserved many rights as to certain corporate stocks and provided that such stocks should go to his son and his daughter on his death. In addition, he made a number of outright gifts to them in the same year. In 1963, prior to the death of decedent's son, such son conveyed outright to his spouse certain of the items he had in turn received outright from his father the previous year.

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In 1962, decedent created a trust in which he reserved many rights as to certain corporate stocks and provided that such stocks should go to his son and his daughter on his death. In addition, he made a number of outright gifts to them in the same year. In 1963, prior to the death of decedent's son, such son conveyed outright to his spouse certain of the items he had in turn received outright from his father the previous year. In addition, upon the son's death in late 1963, his spouse succeeded to his interest in the above-mentioned trust. Held, that decedent made no taxable gift to his…

1Opinion of the Court

Estate of William Mandels, Deceased, Estelle Mandels, Distributee, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent

Estate of Mandels v. Commissioner

Docket Nos. 4848-70, 6903-70, 8520-72, 8530-72

United States Tax Court

64 T.C. 61; 1975 U.S. Tax Ct. LEXIS 161;

April 17, 1975, Filed

Decisions will be entered for the petitioners in docket Nos. 4848-70, 8520-72, and 8530-72.

Decision will be entered under Rule 155 in docket No. 6903-70.

In 1962, decedent created a trust in which he reserved many rights as to certain corporate stocks and provided that such stocks should go to his…

2Cases cited35 opinions

  1. Estate of Sanford v. CommissionerSupreme Court of the United States · 1939
  2. Burnet v. GuggenheimSupreme Court of the United States · 1933
  3. Estate of Horvath v. CommissionerUnited States Tax Court · 1973
  4. Hulburd v. CommissionerSupreme Court of the United States · 1935
  5. Schuster v. CommissionerUnited States Tax Court · 1959

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