Legal Opinion

Beck v. Commissioner

United States Board of Tax Appeals

Decided December 20, 1940No. Docket No. 99439PublishedCited by 4 opinions

GIFT TAX - INCOME USED FOR BENEFIT OF GRANTOR. - Grantor, providing that income of an irrevocable funded insurance trust for the benefit of his wife and daughters should be used to pay premiums on insurance on his life, has thus reserved to himself economic benefits in the property, the value of which was not a taxable gift.

1Opinion of the Court

OPINION.

Murdock :

The Commissioner determined a deficiency of $7,172 in gift tax for the calendar year 1935. The Board adopts as its findings of fact the facts as stipulated by the parties.

The petitioner created an irrevocable funded insurance trust on August 6, 1935, and transferred to the trustee securities having a value in excess of $172,000, together with seven policies of insurance upon his life. The deed of trust provided that the net income of the trust should be applied during the lifetime of the petitioner to the payment of the net premiums, after deducting dividends, upon the…

2Cases cited4 opinions

  1. Burnet v. GuggenheimSupreme Court of the United States · 1933
  2. Burnet v. WellsSupreme Court of the United States · 1933
  3. Rasquin v. HumphreysSupreme Court of the United States · 1939
  4. Guy T. Helvering, Commissioner of Internal Revenue v. Edmund O. Schweitzer.Supreme Court of the United States · 1935

3Cited by4 opinions

  1. United States Holding Co. v. CommissionerUnited States Tax Court · 1965
  2. Beck v. CommissionerUnited States Board of Tax Appeals · 1940
  3. McCormack v. CommissionerUnited States Board of Tax Appeals · 1941
  4. United States Holding Co. v. CommissionerUnited States Tax Court · 1965

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