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Taxation - Federal Gift Tax - Integration With Income Tax, Katherine Kempfer
Taxation - Federal Gift Tax - Integration With Income Tax, Katherine Kempfer
Michigan Law Review
Beck in 1935 created an irrevocable funded insurance trust of $172,000 in securities together with seven policies of insurance on his life. The income from the securities was to be applied to pay the premiums on the policies and any surplus was to be distributed to his wife and daughter. At grantor's death the proceeds of the policies were to be added to the corpus of the trust and all income was to go to the same beneficiaries for life with remainders over. There was no possibility of reverter in the grantor and no right to alter, modify or revoke …
Taxation - Gift Tax - Transfer In Pursuance Of An Antenuptial Agreement As A Taxable Gift, Michigan Law Review
Taxation - Gift Tax - Transfer In Pursuance Of An Antenuptial Agreement As A Taxable Gift, Michigan Law Review
Michigan Law Review
Plaintiff entered into an antenuptial agreement with his intended wife whereby she waived all rights which she might acquire by virtue of the marriage in certain stock which he owned. In consideration therefor, he transferred to her two annuities and an interest as tenant by the entirety in two parcels of real estate. Plaintiff contended that such transfers did not constitute taxable gifts, and the Board of Tax Appeals decided in his favor. Held, that the transfers were taxable gifts, for a waiver of marriage rights in the property of plaintiff pursuant to an antenuptial agreement did not constitute …
Taxation - Income Tax - Inclusion Of Unpaid Dividends In Decedent's Income, Michigan Law Review
Taxation - Income Tax - Inclusion Of Unpaid Dividends In Decedent's Income, Michigan Law Review
Michigan Law Review
Decedent owned stock in a corporation whose board of directors declared a dividend on April 30, 1934, for the fiscal year ending January 31, 1935, payable to stockholders of record at such times and in such installments as the directors might determine. At the time of decedent's death, October 15, 1934, only one-half of the dividend had been paid to him, but the commissioner included in the gross income of the decedent for the taxable period prior to death the entire amount of the dividend declared. The Board of Tax Appeals reduced this amount to the portion of the dividend …
Taxation - Income Tax - Capital Gains - Cost Basis To Distributee, David N. Mills
Taxation - Income Tax - Capital Gains - Cost Basis To Distributee, David N. Mills
Michigan Law Review
Testator died in 1903, and the executors turned over the residue of his estate to themselves as testamentary trustees in 1905. In 1923, pursuant to the will, trustees delivered part of the original trust property, together with other property purchased with trust funds, to plaintiff, the equitable remainderman under the trust. In 1930 plaintiff sold some of the securities which had constituted the corpus of the trust. In determining the cost basis for the capital gains tax on this transaction, plaintiff claimed that the market value on the date when the trustees delivered the property to him in 1923 should …