Commissioner v. Estate of Field
324 U.S. 113 (1945)

Annotate this Case

U.S. Supreme Court

Commissioner v. Estate of Field, 324 U.S. 113 (1945)

Commissioner v. Estate of Field

No. 578

Argued January 5, 1945

Decided February 5, 1945

324 U.S. 113

Syllabus

1. Decedent made a transfer of property in trust limited in duration to the lives of two nieces. If decedent survived both nieces, the corpus was to go to the decedent, rather than to the beneficiaries named in the trust instrument. The nieces survived the decedent.

Held: that, under § 302(c) of the Revenue Act of 1926, the value of the entire corpus of the trust property at the death of the decedent was includible in the gross estate for the purpose of the federal estate tax. Fidelity-Philadelphia Trust Co. v. Rothensies, ante p. 324 U. S. 108. P. 324 U. S. 115.

2. Since the corpus of the trust did not shed the possibility of reversion until the decedent's death, the value of the entire corpus on the date of death was taxable under § 302(c). P. 324 U. S. 116.

144 F.2d 62 reversed.

Page 324 U. S. 114

Certiorari, 323 U.S. 704, to review the reversal of a decision of the Tax Court, 2 T.C. 21, which sustained the Commissioner's determination of a deficiency in estate taxes.

Official Supreme Court case law is only found in the print version of the United States Reports. Justia case law is provided for general informational purposes only, and may not reflect current legal developments, verdicts or settlements. We make no warranties or guarantees about the accuracy, completeness, or adequacy of the information contained on this site or information linked to from this site. Please check official sources.