Conant v. Commissioner
United States Tax Court
In 1939 petitioner established four trusts and named his wife principal beneficiary in each. He transferred to the four trusts a life insurance policy on his own life and shares of stock in a corporation, some of which shares were pledged to secure petitioner's personal indebtedness. In the taxable years 1940 and 1941, the trustee, upon the direction of the primary beneficiary, paid the premiums on the insurance policy and also paid off the indebtedness.
Read the full summary
In 1939 petitioner established four trusts and named his wife principal beneficiary in each. He transferred to the four trusts a life insurance policy on his own life and shares of stock in a corporation, some of which shares were pledged to secure petitioner's personal indebtedness. In the taxable years 1940 and 1941, the trustee, upon the direction of the primary beneficiary, paid the premiums on the insurance policy and also paid off the indebtedness. Each trust invested the wife with power "to cancel or revoke this trust at any time, in whole or in part," and in the event of such…
1Opinion of the Court
Ralph W. Conant, Petitioner, v. Commissioner of Internal Revenue, Respondent
Conant v. Commissioner
Docket No. 5617
United States Tax Court
7 T.C. 453; 1946 U.S. Tax Ct. LEXIS 113;
July 31, 1946, Promulgated
Decision will be entered under Rule 50.
In 1939 petitioner established four trusts and named his wife principal beneficiary in each. He transferred to the four trusts a life insurance policy on his own life and shares of stock in a corporation, some of which shares were pledged to secure petitioner's personal indebtedness. In the taxable years 1940 and 1941, the trustee, upon the direction of…
Also in this document: Concurrence.
2Cases cited4 opinions
- Mallinckrodt v. CommissionerUnited States Tax Court · 1943
- Driscoll v. CommissionerUnited States Tax Court · 1944
- Newman v. CommissionerUnited States Tax Court · 1945
- Conant v. CommissionerUnited States Tax Court · 1946