Legal Opinion
Stifel v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided May 15, 1952No. 233, Docket 22294PublishedCited by 31 opinions
1Opinion of the Court
FRANK, Circuit Judge.
If an adult had been the beneficiary of each of these trusts, of course the gifts would not have been of future interests, since then (under Article Third) each such adult at any time could have demanded payment of income and (under Article Eleventh) of the corpus. 2 But here we have the following differentiating facts: (1) None of the children could himself make such a demand; he could do so only through a guardian. (2) The donor testified as follows: He had set up the trusts for the express purpose of teaching the three children how to invest their own money; his…
2Cases cited5 opinions
- Fondren v. CommissionerSupreme Court of the United States · 1945
- Commissioner v. DisstonSupreme Court of the United States · 1945
- Kieckhefer v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1951
- Matter of StuartNew York Court of Appeals · 1939
- In Re the Revocation of Letters of General Guardianship Issued to GustowNew York Court of Appeals · 1917
3Cited by31 opinions
- Estate of Cristofani v. CommissionerUnited States Tax Court · 1991
- Thorrez v. CommissionerUnited States Tax Court · 1958
- D. Clifford Crummey v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1968
- Perkins v. CommissionerUnited States Tax Court · 1956
- Gilmore v. CommissionerUnited States Tax Court · 1953
26 more not listed; retrieve them via the Exa API.