Darling v. Commissioner
United States Tax Court
Charitable Deduction -- Remainder Interests. -- Petitioners conveyed to a private trustee remainder interests in improved real property, retaining unto themselves for their lives the right to all the rents, issues, and profits therefrom and the right to occupation, possession, and control thereof, together with the discretion to determine whether the property should be disposed of by sale or exchange and the terms thereof and, also, discretion as to reinvestment of the…
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Charitable Deduction -- Remainder Interests. -- Petitioners conveyed to a private trustee remainder interests in improved real property, retaining unto themselves for their lives the right to all the rents, issues, and profits therefrom and the right to occupation, possession, and control thereof, together with the discretion to determine whether the property should be disposed of by sale or exchange and the terms thereof and, also, discretion as to reinvestment of the proceeds of any sale in either real or personal property. Held, that because of the powers retained by the donor-petitioners,…
1Opinion of the Court
James L. Darling and Marion C. Darling, Petitioners, v. Commissioner of Internal Revenue, Respondent
Darling v. Commissioner
Docket No. 94949
United States Tax Court
43 T.C. 520; 1965 U.S. Tax Ct. LEXIS 134;
January 29, 1965, Filed January 29, 1965, Filed
Decision will be entered under Rule 50.
Charitable Deduction -- Remainder Interests. -- Petitioners conveyed to a private trustee remainder interests in improved real property, retaining unto themselves for their lives the right to all the rents, issues, and profits therefrom and the right to occupation, possession, and control thereof, together…
2Cases cited16 opinions
- Helvering v. R. J. Reynolds Tobacco Co.Supreme Court of the United States · 1939
- Marie H. Hamm v. Commissioner of Internal Revenue, William Hamm, Jr. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
- United States v. MichelSupreme Court of the United States · 1931
- Smith v. ShaughnessySupreme Court of the United States · 1943
- Commissioner v. Estate of SternbergerSupreme Court of the United States · 1955
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