Legal Opinion
Commissioner of Internal Revenue v. Bayne's Estate
Court of Appeals for the Second Circuit
Decided May 10, 1946No. 154PublishedCited by 17 opinions
1Opinion of the Court
SWAN, Circuit Judge.
The question presented is whether the corpus of an irrevocable trust created' in 1922 by Jasper Bayne is includible in the grantor’s estate as a transfer “intended to take effect in possession or enjoyment at or after his death” within the meaning of section 811(c) of the Internal Revenue Code, 26 U.S.C.A. Int.Rev.Code, § 811(c).
The grantor died on August 9, 1941, and the respondent, the Chase National Bank of the City of New York, was duly appointed executor of his estate. Thereafter the Commissioner determined a deficiency in the estate tax, which the Tax Court set aside…
2Cases cited5 opinions
- Hassett v. WelchSupreme Court of the United States · 1938
- Fidelity-Philadelphia Trust Co. v. RothensiesSupreme Court of the United States · 1945
- Commissioner v. Estate of FieldSupreme Court of the United States · 1945
- Commissioner of Internal Revenue v. Hall's EstateCourt of Appeals for the Second Circuit · 1946
- Central Hanover Bank & Trust Co. v. United StatesUnited States Court of Claims · 1945
3Cited by17 opinions
- Commissioner v. Estate of ChurchSupreme Court of the United States · 1949
- Slifka v. JohnsonCourt of Appeals for the Second Circuit · 1947
- In Re Estate of LichtensteinSupreme Court of New Jersey · 1968
- Thomas v. GrahamCourt of Appeals for the Fifth Circuit · 1946
- Commissioner of Internal Revenue v. Singer's EstateCourt of Appeals for the Second Circuit · 1947
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