Cerf v. Commissioner
United States Tax Court
Petitioner had the right to receive during her life all of the income of four trusts which her husband created in 1928 for the benefit of her and their four children. The settlor assigned to the trusts one-half of the renewal commissions which were to become payable to him under a general agency contract with a life insurance company. The trusts could not be amended or revoked without petitioner's consent.
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Petitioner had the right to receive during her life all of the income of four trusts which her husband created in 1928 for the benefit of her and their four children. The settlor assigned to the trusts one-half of the renewal commissions which were to become payable to him under a general agency contract with a life insurance company. The trusts could not be amended or revoked without petitioner's consent. In 1932 the trusts were amended, with petitioner's consent, so as to give the settlor the right to the income for life and the right further to amend or revoke the trusts at his pleasure.…
1Opinion of the Court
OPINION.
Smith, Judge:
This proceeding involves a gift tax deficiency of $4,377.80 for 1932. The respondent has determined that petitioner made gifts to her husband of the income for her life, or the right to receive the income for life, of four trusts which her husband had created for the benefit of her and their four children. The facts are stipulated.
Petitioner is a resident of the State of New Jersey and is the wife of Louis A. Cerf, who is also a resident of that state. She filed her gift tax return for 1932 with the collector of internal revenue for the fifth district of New Jersey.
From…
2Cases cited12 opinions
- Lucas v. EarlSupreme Court of the United States · 1930
- Helvering v. HorstSupreme Court of the United States · 1940
- Corliss v. BowersSupreme Court of the United States · 1930
- Blair v. CommissionerSupreme Court of the United States · 1937
- Estate of Sanford v. CommissionerSupreme Court of the United States · 1939
7 more not listed; retrieve them via the Exa API.
3Cited by13 opinions
- Mallinckrodt v. CommissionerUnited States Tax Court · 1943
- Grant v. CommissionerUnited States Tax Court · 1948
- Grasselli v. CommissionerUnited States Tax Court · 1946
- Estate of Childers v. CommissionerUnited States Tax Court · 1948
- Childers v. CommissionerUnited States Tax Court · 1948
8 more not listed; retrieve them via the Exa API.