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Taxation - Federal Estate Tax - Inter Vivos Trust As Gift To Take Effect In Possession Or Enjoyment At Death, Edmund O'Hare
Taxation - Federal Estate Tax - Inter Vivos Trust As Gift To Take Effect In Possession Or Enjoyment At Death, Edmund O'Hare
Michigan Law Review
On May 14, 1919, decedent set up six trusts, appointing life estates with remainders over. Each trust deed provided: "This Trust may, during the lifetime of the Grantor, be amended or revoked on the joint consent of the Grantor and the Trustees." The remainderman, who was the same person in each trust, was also one of the three trustees. Decedent died on September 4, 1928. The Board of Tax Appeals sustained the contention of the Commissioner of Internal Revenue that the value of the life estates should be included in the decedent's gross estate by virtue of section 302 (c) …