Legal Opinion

Allen v. Commissioner

United States Tax Court

Decided May 15, 1944No. Docket No. 399PublishedCited by 15 opinions

Estate Tax -- Transfer to Take Effect in Possession or Enjoyment at or After Death -- Section 811(c), I. R. C. -- A transfer in trust made by the decedent in 1919 under which he reserved a possibility of reverter in case numerous named beneficiaries should all die without issue, held, not a transfer to take effect in possession or enjoyment at or after death within the meaning of section 811(c), I. R. C., following Frances Biddle Trust, 3 T. C. 832.

1Opinion of the Court

OPINION.

Murdock, Judge-.

An opinion in this case was promulgated on April 4, 1944. It was thereafter reconsidered and rejected by the Court, so that the present opinion now becomes the opinion of the Court in this case.

The Commissioner determined a deficiency in estate tax in the amount of $1,626.64. The error assigned is the action of the Commissioner in including in the gross estate a remainder interest in property held by a trust created by the decedent on June 6, 1919. The parties are in agreement upon all of the facts, and the stipulation filed, together with admissions in the pleadings,…

2Cases cited1 opinion

  1. Frances Biddle Trust v. CommissionerUnited States Tax Court · 1944

3Cited by15 opinions

  1. Hall v. CommissionerUnited States Tax Court · 1946
  2. Walker v. CommissionerUnited States Tax Court · 1944
  3. Estate of Hunnewell v. CommissionerUnited States Tax Court · 1945
  4. Commissioner of Internal Revenue v. Bank of CaliforniaCourt of Appeals for the Ninth Circuit · 1946
  5. Estate of Sloane v. CommissionerUnited States Tax Court · 1944

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