Quatman v. Commissioner
United States Tax Court
Petitioner transferred farm property in trust to pay the net income to his four children until the youngest reached 21 years of age at which time the corpus of the trust was to be paid over to them. Held, the gifts of corpus were gifts of future interests in property. Held, further, the gifts of the right to receive the net income from the property were present interests, the value of which could be determined under sec. 25.2512-5, Gift Tax Regs.
1Opinion of the Court
Frank T. Quatman, Petitioner v. Commissioner of Internal Revenue, Respondent
Quatman v. Commissioner
Docket No. 973-69
United States Tax Court
54 T.C. 339; 1970 U.S. Tax Ct. LEXIS 207;
February 24, 1970, Filed
Decision will be entered under Rule 50.
Petitioner transferred farm property in trust to pay the net income to his four children until the youngest reached 21 years of age at which time the corpus of the trust was to be paid over to them. Held, the gifts of corpus were gifts of future interests in property. Held, further, the gifts of the right to receive the net income from the property were…
2Cases cited25 opinions
- United States v. PelzerSupreme Court of the United States · 1941
- Fondren v. CommissionerSupreme Court of the United States · 1945
- Commissioner v. DisstonSupreme Court of the United States · 1945
- Arnold Van Den Wymelenberg, as of the Estate of Eleanor Van Den Wymelenberg, and Arnold Van Den Wymelenberg v. United StatesCourt of Appeals for the Seventh Circuit · 1968
- Fisher v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1942
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