Coulter v. Commissioner
United States Tax Court
1. In 1920 decedent joined with her three children in the creation of a trust, contributing one-half of the corpus. It was provided that out of the net income she should receive $ 200 per month and such further sum as the trustee might in its absolute discretion determine to be adequate or necessary for her proper support, care, and maintenance.
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1. In 1920 decedent joined with her three children in the creation of a trust, contributing one-half of the corpus. It was provided that out of the net income she should receive $ 200 per month and such further sum as the trustee might in its absolute discretion determine to be adequate or necessary for her proper support, care, and maintenance. It was further provided that if the trustee, in its absolute and uncontrolled discretion, should deem the net income insufficient to provide for the reasonable needs and comforts of the decedent, it was authorized and empowered, as often as it should…
1Opinion of the Court
TURNER, Judge:
The respondent determined an estate tax deficiency of $60,220.62. The issues presented are (1) whether the respondent erred in determining that a certain transfer of property made by decedent in 1920 as one of four grantors of a trust was made In contemplation of death or was intended to take effect in possession or enjoyment at or after death, within the meaning of section 811 (c) and (d) of the Internal Revenue Code, and accordingly should be included in decedent’s gross estate, and (2) whether the respondent erred in determining the value of certain shares of corporate stocks…
2Cases cited14 opinions
- Commissioner v. Estate of HolmesSupreme Court of the United States · 1946
- Helvering v. HelmholzSupreme Court of the United States · 1935
- Fletcher v. Los Angeles Trust & Sav. BankCalifornia Supreme Court · 1920
- Eakle v. IngramCalifornia Supreme Court · 1904
- Neel v. BarnardCalifornia Supreme Court · 1944
9 more not listed; retrieve them via the Exa API.
3Cited by18 opinions
- Estate of Holtz v. CommissionerUnited States Tax Court · 1962
- Moreno v. CommissionerUnited States Tax Court · 1957
- Gramm v. CommissionerUnited States Tax Court · 1951
- Cochran v. CommissionerUnited States Tax Court · 1947
- Klauber v. CommissionerUnited States Tax Court · 1960
13 more not listed; retrieve them via the Exa API.