Estate of Sulovich v. Commissioner
United States Tax Court
In 1959 decedent created five separate savings accounts in his name as trustee for his niece and each of her four children. Decedent never withdrew any money from the accounts and in 1965 he transferred the passbooks representing the trust accounts to his niece.
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In 1959 decedent created five separate savings accounts in his name as trustee for his niece and each of her four children. Decedent never withdrew any money from the accounts and in 1965 he transferred the passbooks representing the trust accounts to his niece. Held, decedent intended to and did make valid inter vivos gifts of the trust accounts at the time he delivered the passbooks and they are, therefore, not includable in decedent's gross estate under either sec. 2038 or sec. 2036. Estate of Michael A. Doyle, 32 T.C. 1209 (1959), distinguished.
1Opinion of the Court
Estate of Semo A. Sulovich, Deceased, Helen Unkovich, Executrix, Petitioner v. Commissioner of Internal Revenue, Respondent
Estate of Sulovich v. Commissioner
Docket No. 8153-73
United States Tax Court
66 T.C. 250; 1976 U.S. Tax Ct. LEXIS 110;
May 17, 1976, Filed
Decision will be entered for the petitioner.
In 1959 decedent created five separate savings accounts in his name as trustee for his niece and each of her four children. Decedent never withdrew any money from the accounts and in 1965 he transferred the passbooks representing the trust accounts to his niece. Held, decedent intended to and did…
2Cases cited23 opinions
- In Re the Accounting of TottenNew York Court of Appeals · 1904
- Fleck v. BaldwinTexas Supreme Court · 1943
- Lord v. New York Life Insurance Co.Texas Supreme Court · 1902
- Land v. MarshallTexas Supreme Court · 1968
- Wells v. SansingTexas Supreme Court · 1952
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