Pleet v. Commissioner
United States Tax Court
1. Gift Tax -- Premiums on Policies Held in Trust. -- Petitioner paid premiums on insurance on the life of his father who transferred the policies in trust. Held, that petitioner's interest in the trust was such that the payment was for his own financial benefit and was not a gift.
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1. Gift Tax -- Premiums on Policies Held in Trust. -- Petitioner paid premiums on insurance on the life of his father who transferred the policies in trust. Held, that petitioner's interest in the trust was such that the payment was for his own financial benefit and was not a gift. Grace R. Seligmann, 9 T. C. 191, followed. 2. Id. -- Transfer in Trust -- Completed Gift. -- In 1934 petitioner and his brother transferred insurance policies, on the life of their father, in trust with reservation of the right to exercise all privileges under the policies and to revoke the trust by their joint…
1Opinion of the Court
OPINION.
Tietjbns, Judge:
Respondent determined a deficiency of $7,737.73 in petitioner’s gift tax for the calendar year 1945 from which determination petitioner appeals.
The petitioner assigns error in respondent’s disallowance of a claimed specific exemption of $30,000 for the year 1945 and determination of net gifts in the amount of $50,732.18 for preceding years in ascertaining the total net gifts for the purpose of computing 1945 gift tax liability. In connection therewith and more particularly, petitioner assigns error in respondent’s determination (1) that the payment by petitioner of…
2Cases cited6 opinions
- Burnet v. GuggenheimSupreme Court of the United States · 1933
- Commissioner v. WemyssSupreme Court of the United States · 1945
- Smith v. ShaughnessySupreme Court of the United States · 1943
- Bolton v. CommissionerUnited States Tax Court · 1943
- Seligmann v. CommissionerUnited States Tax Court · 1947
1 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Commissioner of Internal Revenue v. BergerCourt of Appeals for the Second Circuit · 1953
- Goodnow v. United StatesUnited States Court of Claims · 1962
- Merritt v. CommissionerUnited States Tax Court · 1957
- David Goodnow, Thomas W. Goodnow and Lois Goodnow Jay, Executors of the Last Will and Testament of Margery S. Goodnow, Deceased v. The United StatesUnited States Court of Claims · 1962
- Merritt v. CommissionerUnited States Tax Court · 1957
2 more not listed; retrieve them via the Exa API.