Legal Opinion

Spofford v. Commissioner

United States Board of Tax Appeals

Decided March 10, 1926No. Docket No. 1028Published

1. Certain transfers of real and personal property held not to have been made in contemplation of death. 2. The Commissioner's determination that a transfer of certain bonds was intended to take effect in possession or enjoyment at or after death approved. 3. The provisions of section 402(d) of the Revenue Act of 1918 are not retroactive.

1Opinion of the Court

APPEAL OF HANNHAN M. SPOFFORD, ADMINISTRATRIX OF THE ESTATE OF LUCY M. MILLS, DECEASED.

Spofford v. Commissioner

Docket No. 1028.

United States Board of Tax Appeals

3 B.T.A. 1016; 1926 BTA LEXIS 2510;

March 10, 1926, Decided Submitted August 1, 1925.

1. Certain transfers of real and personal property held not to have been made in contemplation of death.

2. The Commissioner's determination that a transfer of certain bonds was intended to take effect in possession or enjoyment at or after death approved.

3. The provisions of section 402(d) of the Revenue Act of 1918 are not retroactive.

Walter K.…

2Cases cited9 opinions

  1. Shwab v. DoyleSupreme Court of the United States · 1922
  2. Shwab v. DoyleCourt of Appeals for the Sixth Circuit · 1920
  3. Knox v. McElligottSupreme Court of the United States · 1922
  4. Safe Deposit & Trust Co. v. TaitDistrict Court, D. Maryland · 1923
  5. Kissam v. McElligottDistrict Court, S.D. New York · 1920

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