Legal Opinion
Commissioner of Internal Revenue v. Hall's Estate
Court of Appeals for the Second Circuit
Decided January 17, 1946No. 113PublishedCited by 19 opinions
1Opinion of the Court
SWAN, Circuit Judge.
The question presented by this appeal is whether the value of the corpus of an irrevocable trust created in 1929 is includible in the grantor’s estate as a transfer “intended to take effect in possession or enjoyment at or after his death” within the meaning of section 302(c) of the Revenue Act of 1926, 44 Stat. 70, 26 U.S.C.A. Int. Rev.Acts, page 227. The Tax Court decided adversely to the commissioner’s contention, and he seeks reversal of its order.
The facts were stipulated. Frank Hall, grantor of the trust, died testate, a resident of New York City on July 31, 1939.…
2Cases cited14 opinions
- Hassett v. WelchSupreme Court of the United States · 1938
- May v. HeinerSupreme Court of the United States · 1930
- Fidelity-Philadelphia Trust Co. v. RothensiesSupreme Court of the United States · 1945
- Commissioner v. Estate of FieldSupreme Court of the United States · 1945
- Goldstone v. United StatesSupreme Court of the United States · 1945
9 more not listed; retrieve them via the Exa API.
3Cited by19 opinions
- Carlton v. CommissionerUnited States Tax Court · 1960
- Commissioner of Internal Revenue v. Bayne's EstateCourt of Appeals for the Second Circuit · 1946
- Parkinson v. Bradford Trust Co. of Boston (In Re O'Brien)United States Bankruptcy Court, E.D. Virginia · 1985
- United States ex rel. Fong Foo v. ShaughnessyCourt of Appeals for the Second Circuit · 1955
- Commissioner of Internal Revenue v. Singer's EstateCourt of Appeals for the Second Circuit · 1947
14 more not listed; retrieve them via the Exa API.