Barnard v. Commissioner
United States Tax Court
Estate Tax -- Irrevocable Transfer to Take Effect After Death Made Before First Estate Tax Act. -- Value of trust property included in gross estate following Estate of Harold I. Pratt, 5 T. C. 881.
1Opinion of the Court
OPINION.
Murdock, Judge:
The Commissioner determined a deficiency of $7,077.63 in estate tax. The petitioners contend that the Commissioner erred by including in the gross estate $36,815.14 representing the value of property transferred by the decedent in trust on August 26, 1911. The Commissioner held that the transfer took effect in possession or enjoyment at the death of the decedent. The facts have been stipulated.
Jane B. Barnard, the decedent, died testate on July 29,1942, leaving no husband or issue surviving. The estate tax return for her estate was filed with the collector of internal…
2Cases cited4 opinions
- Nichols v. CoolidgeSupreme Court of the United States · 1927
- Hassett v. WelchSupreme Court of the United States · 1938
- Fidelity-Philadelphia Trust Co. v. RothensiesSupreme Court of the United States · 1945
- Pratt v. CommissionerUnited States Tax Court · 1945
3Cited by1 opinion
- Barnard v. CommissionerUnited States Tax Court · 1945