Hutchinson v. Commissioner
United States Tax Court
Petitioners made numerous gifts of stock to various donees, in accordance with an instrument designated "Agreement of Trust." The shares were registered in the names of the donees, subject only to a restriction against transfer for a 10-year period coupled with delivery of the certificates to a bank. Held, that, aside from the income interest, the restriction created a "future interest in property" for purposes of the annual gift tax exclusion. Sec. 2503(b), I.R.C. 1954.
1Opinion of the Court
Laura M. Hutchinson, Petitioner v. Commissioner of Internal Revenue, Respondent; Melvin J. Hutchinson, Petitioner v. Commissioner of Internal Revenue, Respondent
Hutchinson v. Commissioner
Docket Nos. 2601-65, 2602-65
United States Tax Court
47 T.C. 680; 1967 U.S. Tax Ct. LEXIS 127;
March 29, 1967, Filed
Decisions will be entered under Rule 50.
Petitioners made numerous gifts of stock to various donees, in accordance with an instrument designated "Agreement of Trust." The shares were registered in the names of the donees, subject only to a restriction against transfer for a 10-year period coupled…
2Cases cited16 opinions
- United States v. PelzerSupreme Court of the United States · 1941
- Fondren v. CommissionerSupreme Court of the United States · 1945
- Ryerson v. United StatesSupreme Court of the United States · 1941
- Morsman v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1937
- Fisher v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1942
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