Shukert v. Allen
273 U.S. 545 (1927)

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U.S. Supreme Court

Shukert v. Allen, 273 U.S. 545 (1927)

Shukert v. Allen

No. 193

Argued March 4, 7, 1927

Decided March 21, 1927

273 U.S. 545

Syllabus

A conveyance of securities made before the testator's death and not in contemplation of it, in trust to accumulate the income until a distant date specified, and then to divide the fund among his children, designated by name as the beneficiaries, vested the interests of his children when it was executed, and was not "intended to take effect in possession or enjoyment at or after his death" within the meaning of § 402(c), Revenue Act of 1918. P. 273 U. S. 547.

6 F.2d 551 reversed.

Certiorari (269 U.S. 543) to a judgment of the circuit court of appeals which affirmed a judgment of the district

Page 273 U. S. 546

court (300 F. 754) directing a verdict for the collector in an action to recover money paid under protest as a federal estate tax.

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