Legal Opinion

Hopper v. Commissioner

United States Tax Court

Decided April 26, 1954No. Docket Nos. 38586, 38587, 38588Published

Estate Tax -- Transfer in Contemplation of Death -- Transfer in Trust With Reservation of Life Estate -- Sec. 811 (c) (1) (A), I. R. C. -- A transfer in trust of a large part of the grantor's assets with a life estate retained by the grantor and remainder to benefit her children and their issue was not made in contemplation of death. Welch v. Hassett, 90 F. 2d 833, followed.

1Opinion of the Court

Estate of Charlotte A. Hopper, Deceased, The Hartford-Connecticut Trust Company, Executor, et al., Petitioners, 1 v. Commissioner of Internal Revenue, Respondent

Hopper v. Commissioner

Docket Nos. 38586, 38587, 38588

United States Tax Court

22 T.C. 138; 1954 U.S. Tax Ct. LEXIS 233;

April 26, 1954, Filed April 26, 1954, Filed

Decisions will be entered under Rule 50.

Estate Tax -- Transfer in Contemplation of Death -- Transfer in Trust With Reservation of Life Estate -- Sec. 811 (c) (1) (A), I. R. C. -- A transfer in trust of a large part of the grantor's assets with a life estate retained by the…

2Cases cited7 opinions

  1. Hassett v. WelchSupreme Court of the United States · 1938
  2. Commissioner v. Estate of ChurchSupreme Court of the United States · 1949
  3. Welch v. HassettCourt of Appeals for the First Circuit · 1937
  4. Farnum v. CommissionerUnited States Tax Court · 1950
  5. Welch v. HassettDistrict Court, D. Massachusetts · 1936

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