Legal Opinion

United States Trust Co. v. Commissioner

United States Board of Tax Appeals

Decided April 29, 1925No. Docket No. 665Published

1. The Board has jurisdiction of an appeal from a determination of the Commissioner, made subsequent to the enactment of the Revenue Act of 1924, denying a claim in abatement of estate taxes assessed prior to the date of such enactment.

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1. The Board has jurisdiction of an appeal from a determination of the Commissioner, made subsequent to the enactment of the Revenue Act of 1924, denying a claim in abatement of estate taxes assessed prior to the date of such enactment. Appeal of Peter Reinberg Estate,1 B.T.A. 953, cited and approved. 2. The cancellation by a father of a promissory note in his favor executed by his son, under circumstances set out in this appeal, held to have been a transfer in praesenti, the possession and enjoyment of which vested immediately in the son and were not postponed to take effect at or after the…

1Opinion of the Court

Appeal of UNITED STATES TRUST COMPANY OF NEW YORK, et al., Executors of FRANCIS S. SMITHERS, deceased.

United States Trust Co. v. Commissioner

Docket No. 665.

United States Board of Tax Appeals

1 B.T.A. 1086; 1925 BTA LEXIS 2679;

April 29, 1925, decided Submitted February 10, 1925.

1. The Board has jurisdiction of an appeal from a determination of the Commissioner, made subsequent to the enactment of the Revenue Act of 1924, denying a claim in abatement of estate taxes assessed prior to the date of such enactment. Appeal of Peter Reinberg Estate,1 B.T.A. 953, cited and approved.

2. The cancellation…

2Cases cited2 opinions

  1. Kransz v. CommissionerUnited States Board of Tax Appeals · 1925
  2. United States Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1925

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