Bridgeport City Trust Co. v. Commissioner
United States Board of Tax Appeals
Where a decedent created a trust for the benefit of his children and grandchildren, reserving only a power to alter the disposition of the trust income among the several beneficiaries, it is held: (1) The value of the corpus is not includable in the decedent's gross estate either as a transfer to take effect at or after death under section 302(c) of the Revenue Act of 1926, or as a transfer subject to a power to alter, amend, or revoke under section 302(d) of the Revenue Act…
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Where a decedent created a trust for the benefit of his children and grandchildren, reserving only a power to alter the disposition of the trust income among the several beneficiaries, it is held: (1) The value of the corpus is not includable in the decedent's gross estate either as a transfer to take effect at or after death under section 302(c) of the Revenue Act of 1926, or as a transfer subject to a power to alter, amend, or revoke under section 302(d) of the Revenue Act of 1926. Waldemar R. Helmholz, Executor,28 B.T.A. 165; affd., 75 Fed.(2d) 245; affd., 296 U.S. 93; and Charles H. W.…
1Opinion of the Court
*192OPINION.
Leech:
Section 302 (c) of the Revenue Act of 1926, as originally enacted, and so far as material, reads as follows:
The value of the gross estate of the decedent shall be determined by including the value at the time of his death of all property, real or personal, tangible or intangible, wherever situated—
*193(c) To the extent of any interest therein of which the decedent has at any time made a transfer, by trust or otherwise, in contemplation of or intended to take effect in possession or enjoyment at or after his death, except in case of a bona fide sale for an adequate and full…
2Cases cited3 opinions
- Hassett v. WelchSupreme Court of the United States · 1938
- Porter v. CommissionerSupreme Court of the United States · 1933
- Helvering v. HelmholzSupreme Court of the United States · 1935
3Cited by1 opinion
- Bridgeport City Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1940