Legal Opinion

Selznick v. Commissioner

United States Tax Court

Decided November 28, 1950No. Docket No. 14985PublishedCited by 29 opinions

The decedent created an irrevocable trust on January 29, 1932, to which and prior to June 7, 1932, he transferred insurance contracts and bonds. The trust provided for the income therefrom to be paid to the decedent for his life in "convenient installments as directed by the" decedent and that income accrued at the decedent's death be paid to the next trust beneficiary.

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The decedent created an irrevocable trust on January 29, 1932, to which and prior to June 7, 1932, he transferred insurance contracts and bonds. The trust provided for the income therefrom to be paid to the decedent for his life in "convenient installments as directed by the" decedent and that income accrued at the decedent's death be paid to the next trust beneficiary. Under the terms of the trust the decedent could cancel the insurance policies and the proceeds thereof would become part of the corpus, the investment of which he could direct and receive the income from. At the decedent's…

1Opinion of the Court

SUPPLEMENTAL OPINION.

Van Fossan, Judge:

The respondent determined a deficiency of $384,634.05 in the estate tax liability of the Estate of Myron Selznick, deceased. On June 23, 1947, the executors of the Estate of Myron Selznick petitioned this Court for a redetermination of the deficiency. The parties came to agreement and settled by stipulation many of the issues from which a large part of the deficiency arose. On April 1, 1949, a Memorandum Opinion of this Court was entered which sustained the respondent’s inclusion in the gross estate under section 811 (c), Internal Revenue Code, of…

2Cases cited4 opinions

  1. May v. HeinerSupreme Court of the United States · 1930
  2. Commissioner v. Estate of ChurchSupreme Court of the United States · 1949
  3. Cyrus H. McCormick v. David BurnetSupreme Court of the United States · 1931
  4. Burnet v. Northern Trust Co.Supreme Court of the United States · 1931

3Cited by29 opinions

  1. Schwager v. CommissionerUnited States Tax Court · 1975
  2. Karagheusian v. CommissionerUnited States Tax Court · 1955
  3. Carlton v. CommissionerUnited States Tax Court · 1960
  4. Fruehauf v. CommissionerUnited States Tax Court · 1968
  5. Hubbard v. CommissionerUnited States Tax Court · 1956

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