Palmer v. Commissioner
United States Board of Tax Appeals
1. Held, that by the execution of a trust agreement the petitioner, as grantor, irrevocably conveyed in praesenti his legal title to certain stock to the trust thereby created and irrevocably conveyed in praesenti the beneficial interest to his wife for life, with remainder interests to his children and their issue. 2. Held, that the execution of the trust agreement effectively passed title to petitioner, as trustee, without manual delivery and despite the fact that the…
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1. Held, that by the execution of a trust agreement the petitioner, as grantor, irrevocably conveyed in praesenti his legal title to certain stock to the trust thereby created and irrevocably conveyed in praesenti the beneficial interest to his wife for life, with remainder interests to his children and their issue. 2. Held, that the execution of the trust agreement effectively passed title to petitioner, as trustee, without manual delivery and despite the fact that the stock transferred in trust remained registered in the petitioner's name and pledged as collateral security for certain…
1Opinion of the Court
CARLETON H. PALMER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Palmer v. Commissioner
Docket No. 89854.
United States Board of Tax Appeals
40 B.T.A. 1002; 1939 BTA LEXIS 765;
December 5, 1939, Promulgated
1. Held, that by the execution of a trust agreement the petitioner, as grantor, irrevocably conveyed in praesenti his legal title to certain stock to the trust thereby created and irrevocably conveyed in praesenti the beneficial interest to his wife for life, with remainder interests to his children and their issue.
2. Held, that the execution of the trust agreement effectively…
2Cases cited1 opinion
- Palmer v. CommissionerUnited States Board of Tax Appeals · 1939