Camden Safe Deposit & Trust Co. v. Commissioner
United States Board of Tax Appeals
1. Property over which a decedent had a general power of appointment is not relieved from the Federal estate tax (sec. 302(f), Revenue Act of 1926) either because it is not part of the decedent's estate under local law and the appointee takes from the donor, or because the donee exercised the power in favor of one who would have taken the property under the donor's will if the power had not been exercised. 2. A power to appoint to "such person or persons as [the donee] by…
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1. Property over which a decedent had a general power of appointment is not relieved from the Federal estate tax (sec. 302(f), Revenue Act of 1926) either because it is not part of the decedent's estate under local law and the appointee takes from the donor, or because the donee exercised the power in favor of one who would have taken the property under the donor's will if the power had not been exercised. 2. A power to appoint to "such person or persons as [the donee] by last will and testament may direct", held a general power within sec. 302(f); and its character as such is unaffected by…
1Opinion of the Court
CAMDEN SAFE DEPOSIT AND TRUST COMPANY AND GWENDOLYN TAYLOR LEONARDS, EXECUTORS, UNDER THE WILL OF G. WILBUR TAYLOR, DECEASED, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Camden Safe Deposit & Trust Co. v. Commissioner
Docket No. 67265.
United States Board of Tax Appeals
30 B.T.A. 287; 1934 BTA LEXIS 1351;
April 3, 1934, Promulgated
1. Property over which a decedent had a general power of appointment is not relieved from the Federal estate tax (sec. 302(f), Revenue Act of 1926) either because it is not part of the decedent's estate under local law and the appointee takes from the…
2Cases cited1 opinion
- Camden Safe Deposit & Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1934