Bridgeport City Trust Co. v. Commissioner
United States Board of Tax Appeals
Where a decedent created a trust for the benefit of his children and grandchildren, reserving only a power to alter the disposition of the trust income among the several beneficiaries, it is held: (1) The value of the corpus is not includable in the decedent's gross estate either as a transfer to take effect at or after death under section 302(c) of the Revenue Act of 1926, or as a transfer subject to a power to alter, amend, or revoke under section 302(d) of the Revenue Act…
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Where a decedent created a trust for the benefit of his children and grandchildren, reserving only a power to alter the disposition of the trust income among the several beneficiaries, it is held: (1) The value of the corpus is not includable in the decedent's gross estate either as a transfer to take effect at or after death under section 302(c) of the Revenue Act of 1926, or as a transfer subject to a power to alter, amend, or revoke under section 302(d) of the Revenue Act of 1926. Waldemar R. Helmholz, Executor,28 B.T.A. 165; affd., 75 Fed.(2d) 245; affd., 296 U.S. 93; and Charles H. W.…
1Opinion of the Court
THE BRIDGEPORT CITY TRUST COMPANY AND ARTHER E. ALLING, EXECUTORS OF THE ESTATE OF NOYES E. ALLING, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Bridgeport City Trust Co. v. Commissioner
Docket No. 87136.
United States Board of Tax Appeals
41 B.T.A. 191; 1940 BTA LEXIS 1219;
January 26, 1940, Promulgated
Where a decedent created a trust for the benefit of his children and grandchildren, reserving only a power to alter the disposition of the trust income among the several beneficiaries, it is held: (1) The value of the corpus is not includable in the decedent's gross estate either…
2Cases cited5 opinions
- Hassett v. WelchSupreme Court of the United States · 1938
- Helvering v. HelmholzSupreme Court of the United States · 1935
- Foster v. CommissionerUnited States Board of Tax Appeals · 1932
- Helmholz v. CommissionerUnited States Board of Tax Appeals · 1933
- Bridgeport City Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1940