Legal Opinion

Connell v. Commissioner

United States Tax Court

Decided August 25, 1953No. Docket No. 33463Published

Money transferred by decedent to one of his sons as trustee for himself and 9 brothers and sisters with the understanding that it was to be returned to the decedent in exchange for promissory notes payable respectively to each of decedent's 10 children, held, not completed gifts.

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Money transferred by decedent to one of his sons as trustee for himself and 9 brothers and sisters with the understanding that it was to be returned to the decedent in exchange for promissory notes payable respectively to each of decedent's 10 children, held, not completed gifts. Consequently the loans represented by 19 of the 20 notes so given and not paid off prior to decedent's death, held not to be indebtedness contracted bona fide and for an adequate and full consideration in money or money's worth so as to be deductible from decedent's gross estate under section 812 (b) (3), Internal…

1Opinion of the Court

Estate of John Edward Connell, Alma C. Gaffney, Frank E. Connell and J. Emmett Connell as Executrix and Executors of the Last Will and Testament of John Edward Connell, Deceased, Petitioners, v. Commissioner of Internal Revenue, Respondent

Connell v. Commissioner

Docket No. 33463

United States Tax Court

20 T.C. 917; 1953 U.S. Tax Ct. LEXIS 76;

August 25, 1953, Promulgated

Decision will be entered under Rule 50.

Money transferred by decedent to one of his sons as trustee for himself and 9 brothers and sisters with the understanding that it was to be returned to the decedent in exchange for promissory…

2Cases cited22 opinions

  1. Burnet v. WellsSupreme Court of the United States · 1933
  2. Johnson v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1936
  3. Gannon v. . McGuireNew York Court of Appeals · 1899
  4. Union Mutual Life Insurance v. BroderickCalifornia Supreme Court · 1925
  5. Crocker v. HallCalifornia Supreme Court · 1908

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