Legal Opinion

Roberts v. Commissioner

United States Tax Court

Decided September 14, 1943No. Docket No. 88Published

Petitioner in 1938 made gifts to her three grandsons of certain guaranteed annuity policies and paid the annual premiums due thereon. In 1939, 1940, and 1941 petitioner paid the premiums on such policies and returned the amounts thereof in her gift tax returns for those years.

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Petitioner in 1938 made gifts to her three grandsons of certain guaranteed annuity policies and paid the annual premiums due thereon. In 1939, 1940, and 1941 petitioner paid the premiums on such policies and returned the amounts thereof in her gift tax returns for those years. In her gift tax returns filed for each of the taxable years petitioner treated the gifts of the annuity premiums as gifts of present interests in property and took the full amount of the exclusions provided by section 1003 (b), Internal Revenue Code. Held, that because of certain restrictive provisions in the annuity…

1Opinion of the Court

Dora Roberts, Petitioner, v. Commissioner of Internal Revenue, Respondent

Roberts v. Commissioner

Docket No. 88

United States Tax Court

2 T.C. 679; 1943 U.S. Tax Ct. LEXIS 69;

September 14, 1943, Promulgated

Decision will be entered for respondent.

Petitioner in 1938 made gifts to her three grandsons of certain guaranteed annuity policies and paid the annual premiums due thereon. In 1939, 1940, and 1941 petitioner paid the premiums on such policies and returned the amounts thereof in her gift tax returns for those years. In her gift tax returns filed for each of the taxable years petitioner treated…

2Cases cited3 opinions

  1. Bolton v. CommissionerUnited States Tax Court · 1943
  2. Perkins v. CommissionerUnited States Tax Court · 1943
  3. Roberts v. CommissionerUnited States Tax Court · 1943

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