Legal Opinion

Siegel v. Commissioner

United States Board of Tax Appeals

Decided April 24, 1930No. Docket No. 18879Published

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

EUGENE SIEGEL, EXECUTOR, ESTATE OF JACOB SIEGEL, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Siegel v. Commissioner

Docket No. 18879.

United States Board of Tax Appeals

19 B.T.A. 683; 1930 BTA LEXIS 2345;

April 24, 1930, Promulgated

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…

2Cases cited1 opinion

  1. Siegel v. CommissionerUnited States Board of Tax Appeals · 1930

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