Estate of Halbach v. Commissioner
United States Tax Court
In an earlier opinion to which this opinion is a supplement (see 71 T.C. 141) we found that decedent's disclaimer of an interest in a trust was a "transfer" for estate tax purposes. The issue in this supplementary opinion is whether or not this transfer was one in contemplation of death. Held: based upon all the facts and circumstances of the case the transfer was not one in contemplation of death.
1Opinion of the Court
ESTATE OF HELEN WODELL HALBACH, DECEASED, JOHN POINIER, EXECUTOR, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Estate of Halbach v. Commissioner
Docket No. 7099-76.
United States Tax Court
T.C. Memo 1980-309; 1980 Tax Ct. Memo LEXIS 275; 40 T.C.M. (CCH) 952; T.C.M. (RIA) 80309;
August 12, 1980, Filed
In an earlier opinion to which this opinion is a supplement (see 71 T.C. 141) we found that decedent's disclaimer of an interest in a trust was a "transfer" for estate tax purposes. The issue in this supplementary opinion is whether or not this transfer was one in contemplation of death.…
2Cases cited20 opinions
- United States v. WellsSupreme Court of the United States · 1931
- Allen v. Trust Co. of Ga.Supreme Court of the United States · 1946
- Cleveland Trust Co. v. United StatesCourt of Appeals for the Sixth Circuit · 1970
- Estate of Johnson v. CommissionerUnited States Tax Court · 1948
- Estate of Ford v. CommissionerUnited States Tax Court · 1969
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