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Estate of Sanford Vs. Commissioner
Cites for this judgment
- US Supreme Court
- Nov 06, 1939
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U.S. 39 (1939) U.S. Supreme Court Estate of Sanford v. CommissionerSearch
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U.S. 39 (1939) Estate of Sanford v. CommissionerSearch
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Act of 1924. MR. JUSTICE STONE delivered the opinion of the Court. This and its companion case, Rasquin v. HumphreysSearch
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his remaining power to modify the trust. After his death in 1928, the Commissioner, following the decision in Hesslein v. HoeySearch
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the Third Circuit, 103 F.2d 81, which followed the decision of the Court of Appeals for the second circuit in Hesslein v. HoeySearch
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passage of control over the economic benefits of property, rather than any technical changes in its title. See Burnet v. GuggenheimSearch
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U. S. 280 , 288 U. S. 287 . Following the enactment of the gift tax statute, this Court, in Reinecke v. NorthernSearch
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at death of a power of revocation of a trust for the benefit of its donor was a taxable transfer. Cf. Saltonstall v. SaltonstallSearch
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Chase National Bank v. UnitedSearch
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States, 278 U. S. 327 , and, similarly, in Porter v. CommissionerSearch
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Act, reenacting in substance 302(d) of the 1924 Act, although enacted after the creation of the trust. Cf. Bullen v. WisconsinSearch
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which was taxed as a transfer, and not the transfer in trust, the statute was not retroactively applied. Cf. Nichols v. CoolidgeSearch
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Corliss v. BowersSearch
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tax was supplementary to the estate tax. The two are in pari materia, and must be construed together. Burnet v. GuggenheimSearch
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the regulation is ambiguous, and without persuasive force in determining the true construction of the statute. Burnet v. ChicagoSearch
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resolved by the practice. We are not bound to accept as controlling stipulations as to questions of law. Swift & Co. v. HockingSearch
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construction of a statute regardless of consequences, even when disclosed in the form of rulings. See Helvering v. NewSearch
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The taxpayers in the present cases are contending Page 308 U. S. 53 for different rulings. In Harriet Rosenau v. Comm'rSearch
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or decision, and which does not appear to have been established before the adoption of the 1932 Act. Cf. McCaughn v. HersheySearch
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Massachusetts Mutual Life Ins. Co. v. UnitedSearch
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Helvering v. NewSearch
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because of the superior knowledge of administrative officers of the administrative needs and convenience, see Brewster v. GageSearch
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administrative practice when it conflicts with an earlier one and is not supported by valid reasons, see Burnet v. ChicagoSearch
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or to meet administrative exigencies, will be accepted as controlling when consistent with our decisions. Morrissey v. CommissionerSearch
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of the Revenue Act of 1932, 47 Stat. 169, shortly after it was decided, in Heiner v. DonnanSearch
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of the Act of 1934, 48 Stat. 680, 758, because Burnet v. GuggenheimSearch
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In the petition for certiorari filed in November, 1937, in Hesslein v. HoeySearch
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U.S. Supreme Court Estate of Sanford v. CommissionerSearch
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Hesslein v. HoeySearch
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See Burnet v. GuggenheimSearch
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Reinecke v. NorthernSearch
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Cf. Saltonstall v. SaltonstallSearch
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Porter v. CommissionerSearch
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Cf. Bullen v. WisconsinSearch
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Cf. Nichols v. CoolidgeSearch
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Burnet v. ChicagoSearch
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Swift & Co. v. HockingSearch
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See Helvering v. NewSearch
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In Harriet Rosenau v. Comm'rSearch
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Act. Cf. McCaughn v. HersheySearch
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Morrissey v. CommissionerSearch
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