Hughes v. Commissioner
United States Board of Tax Appeals
A contract made in 1928 with an insurance company by the decedent during life, whereby she was to receive an annuity, the fund thereafter to be used and distributed among her descendants in prescribed manner and at prescribed times, held to take effect in possession or enjoyment at or after death, and the value thereof held properly within the gross estate of decedent who died in 1935. Revenue Act of 1932, sec. 803(a).
1Opinion of the Court
*1200OPINION.
Sternhagen :
The decedent died in 1935, and the question is whether her estate was subject to the Revenue Act of 1932, section 803 (a), which was a modification of section 302 (c) of the Revenue Act of 1926. In 1928, at a cost of $945,000, she had made a contract with the insurance company by which she received the company’s promise to pay her $2,625 a month for her life and, after her death, to dispose of $900,000 in a prescribed manner among her children, grandchildren, and great-grandchildren. None of the descendants had possession or enjoyment of any part of the fund or its income…
2Cases cited7 opinions
- Helvering v. HallockSupreme Court of the United States · 1940
- Hassett v. WelchSupreme Court of the United States · 1938
- May v. HeinerSupreme Court of the United States · 1930
- Klein v. United StatesSupreme Court of the United States · 1931
- Helvering v. Le GierseSupreme Court of the United States · 1941
2 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Hughes v. Sun Life Assur. Co. of CanadaCourt of Appeals for the Seventh Circuit · 1946
- Brewer v. HassettDistrict Court, D. Massachusetts · 1943
- Schultz v. United StatesCourt of Appeals for the Eighth Circuit · 1944
- Birkbeck v. CommissionerUnited States Board of Tax Appeals · 1942
- Brown v. United StatesDistrict Court, S.D. California · 1941
5 more not listed; retrieve them via the Exa API.