Central Hanover Bank & Trust Co. v. Commissioner
United States Board of Tax Appeals
Members of the New York Stock Exchange are required by its constitution to pay $15 to the trustees of the gratuity fund of the exchange upon being admitted to membership, and to make a voluntary gift of the same amount upon the death of any member of the exchange.
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Members of the New York Stock Exchange are required by its constitution to pay $15 to the trustees of the gratuity fund of the exchange upon being admitted to membership, and to make a voluntary gift of the same amount upon the death of any member of the exchange. Upon proof of death of any member, the exchange is pledged to pay, out of the moneys so collected, the sum of $20,000 to certain beneficiaries designated in the constitution, and members have no right to make any other designation. Failure to continue as a member until death results in the termination of all rights in the fund.…
1Opinion of the Court
OPINION.
Mellott:
The Commissioner determined a deficiency in estate tax in the amount of $1,655.98, all of which is in issue. The sole question is whether or not the sum of $20,000 received by the guardian of decedent’s only child is includable in decedent’s gross estate. The salient facts, all of which were stipulated, may be summarized.
*269The petitioner, a corporation having its principal place of business in New York City, is the duly qualified and acting executor under the last will and testament of Edward L. Norton, deceased, who died prior to January 28,1985. Pauline H. Norton, as general…
2Cases cited25 opinions
- Knowlton v. MooreSupreme Court of the United States · 1900
- Lyeth v. HoeySupreme Court of the United States · 1938
- Liverpool & Great Western Steam Co. v. Phenix InsuranceSupreme Court of the United States · 1889
- Chase National Bank v. United StatesSupreme Court of the United States · 1929
- Tyler v. United StatesSupreme Court of the United States · 1930
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3Cited by4 opinions
- Estate of Roberts v. CommissionerUnited States Tax Court · 1972
- Central Hanover Bank & Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1939
- Estate of Raphael A. Casilear v. CommissionerUnited States Tax Court · 1945
- Estate of Roberts v. CommissionerUnited States Tax Court · 1972