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Commissioner v. Estate of Field, 324 U.S. 113 (1945)
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General SummaryThis case is from a collection containing the full text of over 16,000 Supreme Court cases from 1793 to the present. The body of Supreme Court decisions are, effectively, the final interpretation of the Constitution. Only an amendment to the Constitution can permanently overturn an interpretation and this has happened only four times in American history.
Commissioner v. Estate of Field, 324 U.S. 113 (1945)
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Commissioner v. Estate of Field No. 578 Argued January 5, 1945 Decided February 5, 1945 324 U.S. 113
CERTIORARI TO THE CIRCUIT COURT OF APPEALS
FOR THE SECOND CIRCUIT
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. 108. P. 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. 116.
144 F.2d 62 reversed.
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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Chicago: U.S. Supreme Court, "Syllabus," Commissioner v. Estate of Field, 324 U.S. 113 (1945) in 324 U.S. 113 324 U.S. 114. Original Sources, accessed November 25, 2024, http://originalsources.com/Document.aspx?DocID=NDKLH66WC3NZKJW.
MLA: U.S. Supreme Court. "Syllabus." Commissioner v. Estate of Field, 324 U.S. 113 (1945), in 324 U.S. 113, page 324 U.S. 114. Original Sources. 25 Nov. 2024. http://originalsources.com/Document.aspx?DocID=NDKLH66WC3NZKJW.
Harvard: U.S. Supreme Court, 'Syllabus' in Commissioner v. Estate of Field, 324 U.S. 113 (1945). cited in 1945, 324 U.S. 113, pp.324 U.S. 114. Original Sources, retrieved 25 November 2024, from http://originalsources.com/Document.aspx?DocID=NDKLH66WC3NZKJW.
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