Hallock v. Commissioner
United States Board of Tax Appeals
1. GROSS ESTATE - TRUST. - Decedent transferred a portion of his property to a trustee, the income to be paid to his divorced wife. Trust instrument provided that if beneficiary predeceased him the property was to be delivered over to him, but if he predeceased the beneficiary it was to be delivered over to his children. Beneficiary outlived settlor.
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1. GROSS ESTATE - TRUST. - Decedent transferred a portion of his property to a trustee, the income to be paid to his divorced wife. Trust instrument provided that if beneficiary predeceased him the property was to be delivered over to him, but if he predeceased the beneficiary it was to be delivered over to his children. Beneficiary outlived settlor. Held, that the transfer to the trustee was not "intended to take effect in possession or enjoyment at or after his death" and the property transferred is not includable in his gross estate under section 302(c) of the Revenue Act of 1926.…
1Opinion of the Court
MARY Q. HALLOCK AND CENTRAL UNITED NATIONAL BANK OF CLEVELAND, TRUSTEES, PETITIONERS, ET AL., 1v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Hallock v. Commissioner
Docket Nos. 76802, 76803, 76927.
United States Board of Tax Appeals
34 B.T.A. 575; 1936 BTA LEXIS 676;
May 19, 1936, Promulgated
1. GROSS ESTATE - TRUST. - Decedent transferred a portion of his property to a trustee, the income to be paid to his divorced wife. Trust instrument provided that if beneficiary predeceased him the property was to be delivered over to him, but if he predeceased the beneficiary it was to be delivered over to…
2Cases cited10 opinions
- Reinecke v. Northern Trust Co.Supreme Court of the United States · 1929
- Nichols v. CoolidgeSupreme Court of the United States · 1927
- Helvering v. City Bank Farmers Trust Co.Supreme Court of the United States · 1935
- Helvering v. St. Louis Union Trust Co.Supreme Court of the United States · 1935
- Becker v. St. Louis Union Trust Co.Supreme Court of the United States · 1935
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