Estate of Valentine v. Commissioner
United States Tax Court
Decedent, on June 6, 1932, made a transfer in trust, which provided, inter alia, that the trustees pay to her from the principal of the trust corpus $ 150,000 annually, and upon her death the remaining principal of the corpus was to be divided among designated heirs. The value of this reversionary interest immediately before her death in 1965 at the age of 95 exceeded 5 percent of the value of the property transferred to the trust.
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Decedent, on June 6, 1932, made a transfer in trust, which provided, inter alia, that the trustees pay to her from the principal of the trust corpus $ 150,000 annually, and upon her death the remaining principal of the corpus was to be divided among designated heirs. The value of this reversionary interest immediately before her death in 1965 at the age of 95 exceeded 5 percent of the value of the property transferred to the trust. In filing the estate tax return for decedent's estate, the executors in the computation of the gross estate included, on account of her right to annual invasions…
1Opinion of the Court
OPINION
Withey, Judge:
The respondent, in docket No. 3379-88, determined an estate tax deficiency in the amount of $239,168.95 and addressed his notice to Estate of May L. Valentine, deceased, Lester Armour and T. Stanton Armour as coexecutors. In docket No. 3380-68, respondent determined a deficiency in the same amount against the May L. Valentine, June 6, 1932 Trust, Lester Armour and Patrick A. Valentine, eotrustees, as a transferee and beneficiary of the Estate of May L. Valentine, deceased, Lester Armour and T. Stanton Armour, coexecutors.
In these consolidated cases, the petitioners in…
2Cases cited26 opinions
- Helvering v. HallockSupreme Court of the United States · 1940
- Fidelity-Philadelphia Trust Co. v. RothensiesSupreme Court of the United States · 1945
- Commissioner v. Estate of FieldSupreme Court of the United States · 1945
- Goldstone v. United StatesSupreme Court of the United States · 1945
- Liebmann v. HassettCourt of Appeals for the First Circuit · 1945
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3Cited by1 opinion
- Estate of Valentine v. CommissionerUnited States Tax Court · 1970