Siegel v. Commissioner
United States Board of Tax Appeals
The decedent transferred certain property on May 21, 1918. He died January 18, 1924. The respondent included the value of the property transferred in the decedent's gross estate under section 402(c) of the Revenue Act of 1921. The transfer was not made in contemplation of death; it was not intended to take effect in possession or enjoyment at or after the decedent's death; and in any event, the transaction constituted a bona fide sale for a fair consideration in money or…
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The decedent transferred certain property on May 21, 1918. He died January 18, 1924. The respondent included the value of the property transferred in the decedent's gross estate under section 402(c) of the Revenue Act of 1921. The transfer was not made in contemplation of death; it was not intended to take effect in possession or enjoyment at or after the decedent's death; and in any event, the transaction constituted a bona fide sale for a fair consideration in money or money's worth.
1Opinion of the Court
*686OPINION.
Murdock:
Section 402 (c) of the Revenue Act of 1921 provides that there shall be included in the value of a decedent’s gross estate, the value at the time of his death of all property—
To the extent of any interest therein of which the decedent has at any time made a transfer, or with respect to which he has at any time created a trust, in contemplation of or intended to take effect in possession or enjoyment at or after his death (whether such transfer or trust is made or created before or after the passage of this Act), except in case of a bona fide sale for a fair consideration in…
2Cases cited3 opinions
- Nichols v. CoolidgeSupreme Court of the United States · 1927
- Ferguson v. DicksonCourt of Appeals for the Third Circuit · 1924
- Polk v. MilesDistrict Court, D. Maryland · 1920
3Cited by2 opinions
- Heiner v. DonnanSupreme Court of the United States · 1932
- Siegel v. CommissionerUnited States Board of Tax Appeals · 1930