Duncan v. Commissioner
United States Tax Court
Decedent in 1924 conveyed certain property in trust, reserving to himself a life interest. The trust was to continue for the lives of his son and a grandson, and it provided that upon its termination, if he were still living, the corpus should revert to decedent. Held, that under section 811 (c), I. R. C., the value of the trust corpus as of the date of decedent's death is includible in his gross estate for estate tax purposes.
1Opinion of the Court
OPINION.
Leech, Judge-.
The petitioners assign as error the action of respondent in including in the gross estate of the decedent any part of the value of the property conveyed in trust on January 23,1924. However, upon the hearing of the proceeding, the petitioners based their attack upon the theory that only so much of the value of the trust estate was includible for estate tax purposes as was represented by the value at the time of the transfer in trust of the reversion retained by the decedent. Prior to the filing of briefs herein the cases of Commissioner v. Field, 324 U. S. 113, and…
2Cases cited6 opinions
- Helvering v. HallockSupreme Court of the United States · 1940
- Fidelity-Philadelphia Trust Co. v. RothensiesSupreme Court of the United States · 1945
- Commissioner v. Estate of FieldSupreme Court of the United States · 1945
- Frances Biddle Trust v. CommissionerUnited States Tax Court · 1944
- Fahnestock v. CommissionerUnited States Tax Court · 1945
1 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Hughes v. CommissionerUnited States Tax Court · 1946
- Friedman v. CommissionerUnited States Tax Court · 1947
- National City Bank of New York v. CommissionerUnited States Tax Court · 1946
- Estate of Valentine v. CommissionerUnited States Tax Court · 1970
- National City Bank v. CommissionerUnited States Tax Court · 1946
5 more not listed; retrieve them via the Exa API.