Legal Opinion

Estate of Hull v. Commissioner

Court of Appeals for the Third Circuit

Decided November 29, 1963No. 14393PublishedCited by 4 opinions

1Opinion of the Court

HASTIE, Circuit Judge.

In this case the Tax Court, sustaining a ruling of the Commissioner, has decided that Arthur Hull's irrevocable gratuitous transfer of full ownership rights in 15 *368policies of insurance on his own life to his three daughters equally, as accomplished about two and one-half years before his death, was a transfer “in contemplation of his death” within the meaning of section 2035 of the 1954 Internal Revenue Code. Accordingly, the court required that the proceeds of these policies upon the death of the insured, a total of $130,923.38, be included in his gross estate for…

2Cases cited5 opinions

  1. City Bank Farmers Trust Co. v. McGowanSupreme Court of the United States · 1945
  2. Frank J. Valetti and Sarah J. Valetti v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1958
  3. Hull v. CommissionerUnited States Tax Court · 1962
  4. Belyea's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1953
  5. Estate of Aaron v. CommissionerCourt of Appeals for the Third Circuit · 1955

3Cited by4 opinions

  1. Landorf v. United StatesUnited States Court of Claims · 1969
  2. Estate of Honickman v. CommissionerUnited States Tax Court · 1972
  3. ESTATE OFCourt of Appeals for the Third Circuit · 1963
  4. Estate of Honickman v. CommissionerUnited States Tax Court · 1972

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