Hofford v. Commissioner
United States Tax Court
Held, the decedent did not, in a transfer of certain shares of stock to six irrevocable trusts for the benefit of his wife, daughter, and four grandchildren about three years prior to his death, "retain for his life or for any period not ascertainable without reference to his death or for any period which does not in fact end before his death, the possession or enjoyment of or the right to the income from" the shares of stock thus transferred.
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Held, the decedent did not, in a transfer of certain shares of stock to six irrevocable trusts for the benefit of his wife, daughter, and four grandchildren about three years prior to his death, "retain for his life or for any period not ascertainable without reference to his death or for any period which does not in fact end before his death, the possession or enjoyment of or the right to the income from" the shares of stock thus transferred. The value of such shares at the time of the death of decedent is not includible in his gross estate under the provisions of section 811 (c), Internal…
1Opinion of the Court
SUPPLEMENTAL OPINION.
Black, Judge:
On January 8,1945, this Court promulgated findings of fact and opinion in this proceeding and directed that decision be entered under Rule 50. See Estate of William F. Hofford, 4 T. C. 542. No decision has as yet been entered under Rule 50.
On January 24, 1945, within the 30-day period prescribed by Rule 19 of our Rules of Practice, petitioners, as executors of decedent’s estate, filed a motion for reconsideration. The gist of petitioners’ motion is that there is no factual support for the Tax Court’s decision that (a) the stock transfers in controversy were…
2Cases cited2 opinions
- Holland v. CommissionerUnited States Tax Court · 1943
- Estate of Hofford v. CommissionerUnited States Tax Court · 1945
3Cited by9 opinions
- Bixby v. CommissionerUnited States Tax Court · 1972
- Estate of Gilman v. CommissionerUnited States Tax Court · 1975
- Wheelock v. CommissionerUnited States Tax Court · 1946
- Estate of Scofield v. CommissionerUnited States Tax Court · 1980
- Estate of William L. Belknap v. CommissionerUnited States Tax Court · 1951
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