Legal Opinion

Frank v. Commissioner

United States Board of Tax Appeals

Decided May 11, 1933No. Docket Nos. 53785, 59841Published

A transferred the bulk of his personal property to trustees under a deed of trust which made final disposition of the property upon termination of the trust, and reserved to himself power of revocation and right to direct trustees in sales and reinvestment of trust property. On the same day he executed a codicil to his will. The trust was not revoked; there is no evidence respecting control exercised by A over trust property.

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A transferred the bulk of his personal property to trustees under a deed of trust which made final disposition of the property upon termination of the trust, and reserved to himself power of revocation and right to direct trustees in sales and reinvestment of trust property. On the same day he executed a codicil to his will. The trust was not revoked; there is no evidence respecting control exercised by A over trust property. Upon A's death, his widow elected to take under the will, which left the entire estate to her. The value of the trust property was subjected to Federal estate and state…

1Opinion of the Court

ANNA A. FRANK, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Frank v. Commissioner

Docket Nos. 53785, 59841.

United States Board of Tax Appeals

28 B.T.A. 78; 1933 BTA LEXIS 1190;

May 11, 1933, Promulgated

A transferred the bulk of his personal property to trustees under a deed of trust which made final disposition of the property upon termination of the trust, and reserved to himself power of revocation and right to direct trustees in sales and reinvestment of trust property. On the same day he executed a codicil to his will. The trust was not revoked; there is no evidence respecting…

2Cases cited1 opinion

  1. Frank v. CommissionerUnited States Board of Tax Appeals · 1933

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