Rheinstrom v. Commissioner
United States Board of Tax Appeals
Petitioner created a trust and transferred to it certain property the income of which was to be distributed in the following proportions: 50 percent to her four children in equal amounts, 40 percent to petitioner, and 10 percent to be retained by the trustees in a reserve fund from which the trustees in their absolute discretion could also make payments to petitioner.
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Petitioner created a trust and transferred to it certain property the income of which was to be distributed in the following proportions: 50 percent to her four children in equal amounts, 40 percent to petitioner, and 10 percent to be retained by the trustees in a reserve fund from which the trustees in their absolute discretion could also make payments to petitioner. Held, under authority of Seymour H. Knox,36 B.T.A. 630, petitioner made only one gift and was entitled to an exclusion of $5,000 from value of property given; held, further, petitioner is entitled to deduct the commuted value of…
1Opinion of the Court
KATHERINE S. RHEINSTROM, WHOSE TRUE NAME IS KATHERINE STEWART CLIFFORD, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Rheinstrom v. Commissioner
Docket No. 86035.
United States Board of Tax Appeals
37 B.T.A. 308; 1938 BTA LEXIS 1054;
February 9, 1938, Promulgated
Petitioner created a trust and transferred to it certain property the income of which was to be distributed in the following proportions: 50 percent to her four children in equal amounts, 40 percent to petitioner, and 10 percent to be retained by the trustees in a reserve fund from which the trustees in their absolute…
2Cases cited2 opinions
- Knox v. CommissionerUnited States Board of Tax Appeals · 1937
- Rheinstrom v. CommissionerUnited States Board of Tax Appeals · 1938