Fish v. Commissioner
United States Board of Tax Appeals
1. Value of trust created by decedent held not part of gross estate by reason of decedent's inter vivos power to terminate trust with consent of the life tenant, merely because she was his wife, where she had also the power to appoint the remainder. Louis C. Raegner, Jr., et al. Executors,29 B.T.A. 1243, followed.
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1. Value of trust created by decedent held not part of gross estate by reason of decedent's inter vivos power to terminate trust with consent of the life tenant, merely because she was his wife, where she had also the power to appoint the remainder. Louis C. Raegner, Jr., et al. Executors,29 B.T.A. 1243, followed. Helvering v. Clifford309 U.S. 331, distinguished. 2. Reciprocal trust contemporaneously created by decedent's wife, which gave decedent the trust income for life and a power of appointment, held, taxable as part of decedent's estate. Lehman v. Commissioner, 109 Fed.(2d) 99, and…
1Opinion of the Court
ESTATE OF FREDERICK S. FISH, GRACE S. FISH, EXECUTRIX, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Fish v. Commissioner
Docket No. 99995.
United States Board of Tax Appeals
45 B.T.A. 120; 1941 BTA LEXIS 1173;
September 16, 1941, Promulgated
1. Value of trust created by decedent held not part of gross estate by reason of decedent's inter vivos power to terminate trust with consent of the life tenant, merely because she was his wife, where she had also the power to appoint the remainder. Louis C. Raegner, Jr., et al. Executors,29 B.T.A. 1243, followed. Helvering v. Clifford309 U.S.…
2Cases cited4 opinions
- Helvering v. CliffordSupreme Court of the United States · 1940
- Fish v. CommissionerUnited States Board of Tax Appeals · 1941
- Hughes v. CommissionerUnited States Board of Tax Appeals · 1941
- Raegner v. CommissionerUnited States Board of Tax Appeals · 1934