Carter v. Commissioner
United States Tax Court
Husband and wife respectively executed trust agreements on December 26 and 27, 1935. Husband's trust gave income to wife for life with secondary life estate to his children and remainder to grandchildren. Wife's trust gave income to husband for life with remainder in two-thirds of trust to two children and secondary life estate in one-third of the trust to other child with remainder to his children.
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Husband and wife respectively executed trust agreements on December 26 and 27, 1935. Husband's trust gave income to wife for life with secondary life estate to his children and remainder to grandchildren. Wife's trust gave income to husband for life with remainder in two-thirds of trust to two children and secondary life estate in one-third of the trust to other child with remainder to his children. Held: Trust created by husband is includible in wife's gross estate and trust created by wife is includible in husband's gross estate. Allan S. Lehman et al., Executors, 39 B.T.A. 17, affd. 109 F.…
1Opinion of the Court
BRuce, Judge:
Respondent determined deficiencies in estate tax as follows:
Deficiency
Estate of Laura Carter, Docket No. 62591_$107, 012. 55
Estate of Ernest Trow Carter, Docket No. 62592_ 59,168.93
The issue for decision is whether respondent properly determined that the values of two trusts created by Ernest Trow Carter and Laura Carter, respectively, are respectively includible in the gross estates of Laura and Ernest Trow Carter.
FINDINGS OP PACT.
The stipulated facts are so found and are incorporated herein by this reference. Ernest Trow Carter (hereinafter referred to as Ernest) and Laura…
2Cases cited10 opinions
- Orvis v. HigginsCourt of Appeals for the Second Circuit · 1950
- Lehman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1940
- Cole's Estate v. Com'r of Internal RevenueCourt of Appeals for the Eighth Circuit · 1944
- Hanauer's Estate v. Commissioner of Internal Rev.Court of Appeals for the Second Circuit · 1945
- Lehman v. CommissionerUnited States Board of Tax Appeals · 1939
5 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Krause v. CommissionerUnited States Tax Court · 1972
- Carter v. CommissionerUnited States Tax Court · 1959
- Estate of Bischoff v. CommissionerUnited States Tax Court · 1977
- Estate of Bischoff v. CommissionerUnited States Tax Court · 1977
- Estate of Joseph P. Grace, Deceased, Michael P. Grace, Ii, Joseph Peter Grace, Jr., and Charles MacDonald Grace, Executors v. The United StatesUnited States Court of Claims · 1968
2 more not listed; retrieve them via the Exa API.