Jones v. Commissioner
United States Tax Court
Petitioner created five trusts in the year 1951, and transferred to the trustees of each, without consideration, securities valued at $ 21,645. Four of these trusts were for the respective primary benefits of his four adult children, and the other was for the joint primary benefit of four grandchildren who were minors.
Read the full summary
Petitioner created five trusts in the year 1951, and transferred to the trustees of each, without consideration, securities valued at $ 21,645. Four of these trusts were for the respective primary benefits of his four adult children, and the other was for the joint primary benefit of four grandchildren who were minors. Each of the four children's trusts gave the entire trust income to the primary beneficiary for life, and the remainder to others; and each also granted a power to the corporate trustee to encroach upon the principal of the trust, from time to time when it believed it proper to…
1Opinion of the Court
Pierce, Judge:
Respondent determined deficiencies in gift tax in respect of the petitioner, for the years 1951 and 1952 in the amounts of $4,331.79 and $27.93, respectively.
The issues for decision are:(1) Whether, in determining the amount of petitioner’s gifts for tbe year 1951, there should be allowed pursuant to section 1003 (b) of the 1939 Code,1 four exclusions of not to exceed $3,000 each, in respect of the interests of his four living adult children in four separate irrevocable trusts which he created in said year. The answer depends on whether the values of the present interests (as…
2Cases cited24 opinions
- Ithaca Trust Co. v. United StatesSupreme Court of the United States · 1929
- Henslee v. Union Planters National Bank & Trust Co.Supreme Court of the United States · 1949
- Merchants Nat. Bank of Boston v. CommissionerSupreme Court of the United States · 1943
- Fondren v. CommissionerSupreme Court of the United States · 1945
- Commissioner v. DisstonSupreme Court of the United States · 1945
19 more not listed; retrieve them via the Exa API.
3Cited by17 opinions
- St. Louis Union Trust Company, of the Estate of Frank Landwehr, Deceased v. United StatesCourt of Appeals for the Eighth Circuit · 1967
- George Fischer v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1961
- Calder v. CommissionerUnited States Tax Court · 1985
- Hrobon v. CommissionerUnited States Tax Court · 1964
- Newlin v. CommissionerUnited States Tax Court · 1958
12 more not listed; retrieve them via the Exa API.