Legal Opinion

Estate of Halvor J. T. Jacobsen v. Commissioner

United States Tax Court

Decided December 7, 1950No. Docket No. 22602Unpublished

Estate tax: Contemplation of death. - The decedent transferred property to his wife during his life. The transfers were made at the wife's request and upon the advice of a friend of the wife. The transfers were made nine years prior to the death of the decedent.

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Estate tax: Contemplation of death. - The decedent transferred property to his wife during his life. The transfers were made at the wife's request and upon the advice of a friend of the wife. The transfers were made nine years prior to the death of the decedent. The impelling reasons and dominant purposes for making the transfers were to satisfy the wife's desire for financial independence and her own income, to give recognition of her contributions to their family life, and to overcome family discord and tension caused by the wife's concern over her financial status. The transfers were not a…

1Opinion of the Court

Estate of Halvor J. T. Jacobsen, deceased, Guaranty Trust Company of New York, Executor v. Commissioner.

Estate of Halvor J. T. Jacobsen v. Commissioner

Docket No. 22602.

United States Tax Court

1950 Tax Ct. Memo LEXIS 23; 9 T.C.M. (CCH) 1112; T.C.M. (RIA) 50301;

December 7, 1950

Estate tax: Contemplation of death. - The decedent transferred property to his wife during his life. The transfers were made at the wife's request and upon the advice of a friend of the wife. The transfers were made nine years prior to the death of the decedent. The impelling reasons and dominant purposes for making the…

2Cases cited7 opinions

  1. United States v. WellsSupreme Court of the United States · 1931
  2. Allen v. Trust Co. of Ga.Supreme Court of the United States · 1946
  3. MacAulay v. CommissionerUnited States Tax Court · 1944
  4. Howard v. CommissionerUnited States Tax Court · 1947
  5. Gallery v. CommissionerUnited States Board of Tax Appeals · 1938

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