Estate of Bell v. Commissioner
United States Tax Court
Decedent transferred a United States Treasury note and cash to a trust of which she was one of the cotrustees who had power to distribute all or part of the corpus to the beneficiary "for the purpose of providing her with funds for a home, business, or for any other purpose believed by the Trustees to be for her benefit."
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Decedent transferred a United States Treasury note and cash to a trust of which she was one of the cotrustees who had power to distribute all or part of the corpus to the beneficiary "for the purpose of providing her with funds for a home, business, or for any other purpose believed by the Trustees to be for her benefit." Held, the power exercisable by decedent in conjunction with her cotrustees was not subject to an objective standard with the result that the value of the property which decedent transferred to the trust is includable in decedent's gross estate under sec. 2038(a)(1), I.R.C.…
1Opinion of the Court
Estate of Nathalie F. Bell, Deceased, Gilbert H. Osgood and Chicago Title and Trust Co., Executors, Petitioners v. Commissioner of Internal Revenue, Respondent
Estate of Bell v. Commissioner
Docket No. 7973-74
United States Tax Court
66 T.C. 729; 1976 U.S. Tax Ct. LEXIS 73;
July 22, 1976, Filed
Decision will be entered under Rule 155.
Decedent transferred a United States Treasury note and cash to a trust of which she was one of the cotrustees who had power to distribute all or part of the corpus to the beneficiary "for the purpose of providing her with funds for a home, business, or for any other…
2Cases cited18 opinions
- United States v. O'MALLEYSupreme Court of the United States · 1966
- Jennings v. SmithCourt of Appeals for the Second Circuit · 1947
- Hurd v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1947
- Burke v. BurkeIllinois Supreme Court · 1913
- Pardee v. CommissionerUnited States Tax Court · 1967
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