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Helvering Vs. Hallock

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  • US Supreme Court
  • Jan 29, 1940

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  1. Morsman Vs. Burnet US Supreme Court · Jan 01, 1931
  2. Mccormick Vs. Burnet US Supreme Court · Jan 01, 1931
  3. May Vs. Heiner US Supreme Court · Apr 14, 1930
  4. Smiley Vs. Holm US Supreme Court · Apr 11, 1932
  5. U.S. 106 (1940) U.S. Supreme Court Helvering v. Hallock
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  6. U.S. 106 (1940) Helvering v. Hallock
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  7. Act of 1926, as a transfer intended to take effect in possession or enjoyment at or after the grantor's death. Klein v. United
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  8. c). In its enforcement, Treasury and courts alike encounter three recent decisions of this Court, Klein v. United
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  9. at the time when death brings it into enjoyment. We turn to the cases which beget the difficulties. In Klein v. United
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  10. Klein v. United
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  11. U. S. 39 , 296 U. S. 43 . This was precisely the mode of argument which had been rejected in Klein v. United
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  12. body of law, and to apply their distinctions to the trusts before us. In Nos. 110, 111 and 112 ( Helvering v. Hallock
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  13. Commissioner v. Hallock
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  14. F.2d 1, 3, 4. In No. 183 ( Rothensies v. Huston
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  15. supra, controlling against the inclusion of the trust corpus in the gross estate. Finally, in No. 399 ( Bryant v. Helvering
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  16. the nature of the interest which the decedent in that case retained after his inter vivos transfer. Bryant v. Hackett
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  17. CHIEF JUSTICE concurs in the result upon the ground that each of these cases is controlled by our decision in Klein v. United
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  18. Together with No. 111, Helvering, Commissioner of Internal Revenue v. Hallock
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  19. Executrix, and No. 112, Helvering, Commissioner of Internal Revenue v. Squire
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  20. No. 183, Rothensies, Collector of Internal Revenue v. Huston
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  21. Circuit Court of Appeals for the Third Circuit, argued December 13, 14, 1939, and No. 399, Bryant et al., Executors v. Helvering
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  22. Petitioner's Brief, Klein v. United
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  23. Some indication of the influence of Klein v. United
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  24. States, supra, upon the lower courts may be found in Sargent v. White
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  25. F.2d 410, and Union Trust Co. v. United
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  26. States, 54 F.2d 152, cert. denied, 286 U.S. 547. Cf. Commissioner v. Schwarz
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  27. Elizabeth B. Wallace v. Comm'r
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  28. Louis C. Raegner, Jr. v. Comm'r
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  29. under the New York statutory rule. Cf. Commissioner v. Schwarz
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  30. Flora M. Bonney v. Comm'r
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  31. Cf. Lyeth v. Hoey
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  32. law in another connection by a decision rendered on the same day as were the St. Louis Trust cases. Cf. White v. Poor
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  33. did not constitute a sufficient postponement of the remainder to bring it into the grantor's gross estate. May v. Heiner
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  34. Burnet v. Northern
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  35. by the fact that, in those cases, the majority, in part at least, relied upon the Congressionally discarded May v. Heiner
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  36. a settled principle of internal revenue legislation. Here, unlike the situation in such cases as National Lead Co. v. United
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  37. States, 252 U. S. 140 , 252 U. S. 146 -147, and Murphy Oil Co. v. Burnet
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  38. Smiley v. Holm
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  39. U. S. 355 , 285 U. S. 373 , and Warner v. Goltra
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  40. it cannot be deemed to have bound itself by this change. Art. 17, Reg. 80 (1937 Ed.), p. 42. Cf. Estate of Sanford v. Commissioner
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  41. London Street Tramways Co., Ltd. v. London
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  42. A.C. 375. But the rule is otherwise in the Privy Council. Read v. Bishop
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  43. Lord Wright in Westminster Council v. Southern
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  44. MR. JUSTICE ROBERTS. There is certainly a distinction in fact between the transaction considered in Klein v. United
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  45. and applied by the Board of Tax Appeals, the lower federal courts, and this court, up to the decision of McCormick v. Burnet
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  46. something is not the shifting of possession or beneficial enjoyment from the decedent. This is made clear by Reinecke v. Northern
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  47. transfer, any more than there would be in the case of a similar life estate given A by his grandmother. (This is May v. Heiner
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  48. law, that remainder passes to someone else at his death, such passage renders the transfer taxable. (This is Klein v. United
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  49. can become effective at his death by the shifting of any interest from him, no tax is imposed. (This is McCormick v. Burnet
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  50. and were thereafter developed, in application to specific cases, in a consistent line of authorities. In May v. Heiner
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