Dravo v. Commissioner
United States Board of Tax Appeals
1. Where two brothers and their wives, who had separate estates of their own, each executed contemporaneously certain transfers in trust not in contemplation of death, which transfers were irrevocable except as to certain remainder interests created by the trusts, it is held: (a) None of the parts of the corpora of the trusts which represented life estates irrevocably conveyed to their respective wives are includable in the respective gross estates of the decedents.
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1. Where two brothers and their wives, who had separate estates of their own, each executed contemporaneously certain transfers in trust not in contemplation of death, which transfers were irrevocable except as to certain remainder interests created by the trusts, it is held: (a) None of the parts of the corpora of the trusts which represented life estates irrevocably conveyed to their respective wives are includable in the respective gross estates of the decedents. (b) The values of remainder interests representing parts of the trusts which were payable to such remaindermen as should be…
1Opinion of the Court
*319OPINION.
Black :
In Docket No. 88094 the respondent, under subdivision (c) of section 302 of the Eevenue Act of 1926, as amended, included $395,-000 in the decedent’s gross estate as a result of the transfer in trust made by Francis E. Dravo on January 17, 1931. In Docket No. 89366 the respondent, under subdivisions (c) and (d) of the same act, included $415,000 as a result of the transfer made by Ealph M. Dravo on January 15, 1931. In neither case has the respondent allowed any deduction under section 303 (a) (3) from the amounts thus included under section 302. Petitioners contend that no…
2Cases cited8 opinions
- Helvering v. GowranSupreme Court of the United States · 1937
- Ithaca Trust Co. v. United StatesSupreme Court of the United States · 1929
- Reinecke v. Northern Trust Co.Supreme Court of the United States · 1929
- Hassett v. WelchSupreme Court of the United States · 1938
- May v. HeinerSupreme Court of the United States · 1930
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3Cited by3 opinions
- Estate of Oliver v. CommissionerUnited States Tax Court · 1944
- Dravo v. CommissionerUnited States Board of Tax Appeals · 1939
- Helvering v. HallockSupreme Court of the United States · 1940