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

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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


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.

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