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Articles 1 - 4 of 4
Full-Text Articles in Tax Law
Taxation - Optional Valuation Date Under Federal Estate Tax - Inclusion Of Income Received During Year After Decedents Death In The Valuation Of The Gross Estate, Jay W. Sorge
Michigan Law Review
The executors of three different estates elected the optional valuation date provided in the federal estate tax and were compelled, because of a Treasury regulation, to include rents, interest, and regular dividend payments received during the year after the decedent's death in their valuation of the gross estate. In actions to recover overpayment of the tax, the regulation was upheld by the lower federal courts, and the cases were brought to the Supreme Court by certiorari. Held, regular dividend, interest, and rent payments received by the estate between the decedent's death and the optional valuation date one year later, …
The Impact Of The Law Of Powers Upon Our Internal Revenue Laws, Montgomery B. Angell
The Impact Of The Law Of Powers Upon Our Internal Revenue Laws, Montgomery B. Angell
Michigan Law Review
An interesting difference in view has arisen recently in the halls of the Harvard Law School on the use of powers of appointment under the federal estate tax act. One view is that the chief efficacy today of the power of appointment lies in its capacity for use in tax evasion, which should be corrected. The other view is that there is a salutary tendency toward using sensible and flexible powers of appointment, which should be encouraged in meeting changing and difficult family situations, but which would be checked were the former view accepted. Thus we find here the age-old …
Taxation - Federal Income Tax - Exemption Of Life Insurance Proceeds When Paid In The Form Of Annuity, Spencer E. Irons
Taxation - Federal Income Tax - Exemption Of Life Insurance Proceeds When Paid In The Form Of Annuity, Spencer E. Irons
Michigan Law Review
A taxpayer was the beneficiary of life insurance policies which required the insurance company to make fifty annual payments of $2,000 each. At the death of the insured in 1917, the commuted value of this obligation was $53,000. Prior to 1934, the taxpayer had received seventeen payments, aggregating $45,473.40, no part of which had been reported as income. For the year 1934, the taxpayer received $2,581.40, of which $2,000 was the annual payment, and $581.40 was an "excess interest" dividend. He again failed to include any of the amount in his gross income. The commissioner determined that under the Revenue …
Taxation - Federal Income Tax - Intangible Satisfaction From Gift As Income To The Donor, Walter B. Connolly
Taxation - Federal Income Tax - Intangible Satisfaction From Gift As Income To The Donor, Walter B. Connolly
Michigan Law Review
Respondent, the owner of negotiable bonds, detached from them negotiable interest coupons shortly before their due date and delivered them as a gift to his son, who in the same year collected them at maturity. The commissioner of internal revenue ruled that the interest payments were taxable to the respondent donor. The circuit court of appeals reversed the order of the board of tax appeals sustaining the tax. Held, the commissioner was correct in including such interest payments in the taxable income of the donor. Helvering v. Horst, (U.S. 1940) 61 S. Ct. 144.