Karagheusian v. Commissioner
United States Tax Court
Decedent's wife applied for and received an insurance policy on decedent's life which she transferred in 1928 to a trust, together with certain securities. Both decedent and his wife subsequently made additional transfers of cash or securities to the trust. The income of the trust was to be used first for premiums on the insurance, the excess to be paid to the wife for her life.
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Decedent's wife applied for and received an insurance policy on decedent's life which she transferred in 1928 to a trust, together with certain securities. Both decedent and his wife subsequently made additional transfers of cash or securities to the trust. The income of the trust was to be used first for premiums on the insurance, the excess to be paid to the wife for her life. She had the right to alter, amend, or revoke the trust with the consent of the decedent and their daughter. On decedent's death in 1948 the insurance proceeds were paid to the trust. None of the securities originally…
1Opinion of the Court
OPINION.
Arttndell, Judge:
More than 20 years prior to decedent’s death, his wife, Zabelle, applied for and received an insurance policy in the face amount of $100,000 on the life of decedent. Shortly after receiving the policy, she assigned it, along with certain securities, to a trust set up for the express purpose of holding the policy, its proceeds, and other property.
The trust agreement as subsequently amended provided for its amendment, alteration, or revocation by Zabelle during her lifetime but only with the consent of both the decedent and his daughter, Leila.
The primary question for…
2Cases cited8 opinions
- Guggenheim v. HelveringCourt of Appeals for the Second Circuit · 1941
- Selznick v. CommissionerUnited States Tax Court · 1950
- Estate of Garrett v. CommissionerUnited States Tax Court · 1947
- Koussevitsky v. CommissionerUnited States Tax Court · 1945
- Goldstein's Estate v. United StatesUnited States Court of Claims · 1954
3 more not listed; retrieve them via the Exa API.
3Cited by20 opinions
- Estate of James H. Lumpkin, Jr., Deceased. Christine T. Hamilton v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1973
- Schwager v. CommissionerUnited States Tax Court · 1975
- Estate of Coleman v. CommissionerUnited States Tax Court · 1969
- Selling v. CommissionerUnited States Tax Court · 1955
- Fruehauf v. CommissionerUnited States Tax Court · 1968
15 more not listed; retrieve them via the Exa API.