National City Bank v. Commissioner
United States Tax Court
Decedent in 1921, 1924, and 1925 conveyed certain property to three irrevocable trusts, reserving to himself and his wife the income for life, with income payable upon his death and the death of his wife to his daughter and upon her death to his grandson.
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Decedent in 1921, 1924, and 1925 conveyed certain property to three irrevocable trusts, reserving to himself and his wife the income for life, with income payable upon his death and the death of his wife to his daughter and upon her death to his grandson. The trusts were to continue for the lives of his daughter and his grandson, and the trusts provided that upon their termination, if he were still living, the corpus should revert to decedent; but in case decedent or his wife did not survive the daughter and grandson, the trust corpus was to be paid to the children of the said grandson then…
1Opinion of the Court
OPINION.
Black, Judge:
The question which we have to decide in these proceedings is stated by petitioners in their brief as follows: Whether the values of three irrevocable trusts created by Charles F. Loudon during his lifetime are includible in his gross estate for Federal estate tax purposes under the provisions of section 811 (c) of the Internal Eev-enue Code, printed in the margin.1
The petitioners contend that the trusts in question were not intended by the decedent “to take effect in possession or enjoyment at or after his death” within the meaning of section 811 (c). They support this…
2Cases cited8 opinions
- Hassett v. WelchSupreme Court of the United States · 1938
- May v. HeinerSupreme Court of the United States · 1930
- Fidelity-Philadelphia Trust Co. v. RothensiesSupreme Court of the United States · 1945
- Commissioner v. Estate of FieldSupreme Court of the United States · 1945
- Frances Biddle Trust v. CommissionerUnited States Tax Court · 1944
3 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- National City Bank v. CommissionerUnited States Tax Court · 1946