Ryerson v. United States
312 U.S. 405 (1941)

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U.S. Supreme Court

Ryerson v. United States, 312 U.S. 405 (1941)

Ryerson v. United States

No. 495

Argued January 8, 1941

Decided March 3, 1941

312 U.S. 405

Syllabus

1. A respondent in certiorari is entitled to sustain the judgment upon a ground other than that adopted by the court below. P. 312 U. S. 408.

2. In computing gift taxes under the Revenue Act of 1932, gifts in one trust for several beneficiaries are each entitled to deduction up to $5,000, if they are not gifts of "future interests." Helvering v. Hutchings, ante, p. 312 U. S. 393. P. 312 U. S. 408.

3. Gifts of separate equal shares of the corpus of a trust to each of the two trustees in the event of their joint request that the trust be terminated are gifts upon a contingency which may never happen, and are therefore gifts of "future interests" within the meaning of § 504(b) of the Revenue Act of 1932. United States v. Pelzer, ante, p. 312 U. S. 399. P. 312 U. S. 408.

4. A joint power to two beneficiaries to terminate a trust and thereby acquire the corpus in equal shares is not the equivalent of ownership, since the joint power is not for the joint benefit of the donees, and its exercise could only operate for the benefit of each to the extent of one-half of the trust property, and then only in the event that both agreed to unite in its exercise, and the use and enjoyment of any part of the trust fund by either will be postponed until both join in the exercise of the power. P. 312 U. S. 408.

5. Gifts in trust dependent upon survivorship of one or more persons at the death of the donor are gift of "future interests" within the meaning of § 504(b) of the Revenue Act of 1932. United States v. Pelzer, ante, p. 312 U. S. 399. P. 312 U. S. 409.

114 F.2d 150 affirmed.

Certiorari, 311 U.S. 640, to review a judgment reversing a recovery in the District Court, 28 F.Supp. 265, for alleged overpayment of gift taxes.

Page 312 U. S. 406

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