Legal Opinion
Dominick's Estate v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided January 2, 1946No. 56PublishedCited by 7 opinions
1Opinion of the Court
FRANK, Circuit Judge.
Under Helvering v. Hallock, 309 U.S. 106, 60 S.Ct. 444, 84 L.Ed. 604, 125 A.L.R. 1368, § 811(c) reaches all inter vivos transfers which may be utilized in preference to the making of a will in order to effectuate a disposition of property which will he operative at death.
Taxpayer argues that, as the gift of the ■corpus to the son is dependent only upon his reaching the age of 25, and in no way upon his father’s death, § 811(c) does not .apply. We cannot agree. Until the son ■reached the age of 25, there remained a possibility that the property would revert to the grantor,…
2Cases cited6 opinions
- Helvering v. HallockSupreme Court of the United States · 1940
- Fidelity-Philadelphia Trust Co. v. RothensiesSupreme Court of the United States · 1945
- Commissioner v. Estate of FieldSupreme Court of the United States · 1945
- Goldstone v. United StatesSupreme Court of the United States · 1945
- Commissioner of Internal Revenue v. Irving Trust Co.Court of Appeals for the Second Circuit · 1945
1 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Tarver v. CommissionerUnited States Tax Court · 1956
- In Re Inman's Estate. Shiland v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1953
- Commissioner of Internal Revenue v. Singer's EstateCourt of Appeals for the Second Circuit · 1947
- Inman v. CommissionerUnited States Tax Court · 1952
- Bankers Trust Co. v. HigginsDistrict Court, S.D. New York · 1946
2 more not listed; retrieve them via the Exa API.