Shukert v. Allen, 273 U.S. 545 (1927)

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Shukert v. Allen

No. 193

Argued March 4, 7, 1927
Decided March 21, 1927
273 U.S. 545

CERTIORARI TO THE CIRCUIT COURT OF APPEALS

FOR THE EIGHTH CIRCUIT

Syllabus

A conveyance of securities made before the testator’s death and not in contemplation of it, in trust to accumulate the income until a distant date specified, and then to divide the fund among his children, designated by name as the beneficiaries, vested the interests of his children when it was executed, and was not "intended to take effect in possession or enjoyment at or after his death" within the meaning of § 402(c), Revenue Act of 1918. P. 547.

6 F.2d 551 reversed.

Certiorari (269 U.S. 543) to a judgment of the circuit court of appeals which affirmed a judgment of the district court (300 F. 754) directing a verdict for the collector in an action to recover money paid under protest as a federal estate tax.