Twogood v. Commissioner
United States Tax Court
After 30 years of foreign service in the employ of the Standard Oil Company of New York and its successor companies, the decedent was entitled to retire on an annuity for the remainder of his life under the provisions of a pension plan inaugurated by the employer.
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After 30 years of foreign service in the employ of the Standard Oil Company of New York and its successor companies, the decedent was entitled to retire on an annuity for the remainder of his life under the provisions of a pension plan inaugurated by the employer. Five years prior to the date of his retirement, the decedent elected, under an option provided in the pension plan, to take a reduced annuity on his retirement and in the event his designated dependent survived him, that dependent would receive an annuity for life. Held, under section 811 (c), I. R. C., as amended by P. L. 378…
1Opinion of the Court
OPINION.
Van Fossan, Judge:
The primary issue in this case is whether or not the decedent made a transfer under the provisions of section 811 (c) of the Internal Revenue Code. The pertinent parts of section 811 (c), as amended by P. L. 378 (1949) and made applicable by section 7 (b) thereof to estates of decedents dying after February 10, 1939, are set out in the margin.1
The decedent worked for a company which provided by a pension plan for the retirement of its employees. All bnt a small part of the cost of this plan was paid by the employer. The decedent was entitled to retire on a pension…
2Cases cited1 opinion
- Higgs v. CommissionerUnited States Tax Court · 1949
3Cited by19 opinions
- Fusz v. CommissionerUnited States Tax Court · 1966
- Davis v. CommissionerUnited States Tax Court · 1956
- Estate of Kinney v. CommissionerUnited States Tax Court · 1963
- In Re Estate of Joseph E. Reilly, Deceased. Grace F. Reilly, Administratrix v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1957
- Christiernin v. ManningDistrict Court, D. New Jersey · 1956
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