Cullman v. Commissioner
United States Tax Court
G set up a trust to which she conveyed a $ 290,000 vacation home and retained for herself a one-sixth beneficial interest in the trust. The other five beneficiaries under the trust, each of whom had a one-sixth beneficial interest, were G's husband and their four children. Under trust provisions, restrictions were placed on a beneficiary transferring his interest in the trust.
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G set up a trust to which she conveyed a $ 290,000 vacation home and retained for herself a one-sixth beneficial interest in the trust. The other five beneficiaries under the trust, each of whom had a one-sixth beneficial interest, were G's husband and their four children. Under trust provisions, restrictions were placed on a beneficiary transferring his interest in the trust. Held: For valuation purposes amount of the gift is the value of the property conveyed by G to the trust less the value of the interest retained by G. Amount of the gift is not determined by considering what a one-sixth…
1Opinion of the Court
W. ARTHUR CULLMAN and CECILIA S. CULLMAN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Cullman v. Commissioner
Docket No. 491-80.
United States Tax Court
T.C. Memo 1981-666; 1981 Tax Ct. Memo LEXIS 77; 42 T.C.M. (CCH) 1691; T.C.M. (RIA) 81666;
November 17, 1981.
G set up a trust to which she conveyed a $ 290,000 vacation home and retained for herself a one-sixth beneficial interest in the trust. The other five beneficiaries under the trust, each of whom had a one-sixth beneficial interest, were G's husband and their four children. Under trust provisions, restrictions were placed on a…
2Cases cited11 opinions
- Burnet v. GuggenheimSupreme Court of the United States · 1933
- Smith v. ShaughnessySupreme Court of the United States · 1943
- Robinette v. HelveringSupreme Court of the United States · 1943
- Helvering v. HutchingsSupreme Court of the United States · 1941
- Estate of Cora R. Fitts, Deceased, J. Russel Fitts and Frank E. Tyler, Co-Executors v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1956
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