Add to ORKGWhere two trusts are created by separate donors under circumstances indicating reciprocity, the doctrine of the Lehman case requires that each donor be treated as the grantor of the trust over which he holds various incidents of ownership to the extent that the amounts in the two trusts are equal. For tax purposes the nominal grantors are transposed. The legal basis of this doctrine is the principle of trust law that one who furnishes the consideration for the creation of a trust is the settlor, although in form the trust was created by another. Thus if the settlor of trust A is given the power to invade the corpus of reciprocal trust B, the corpus of trust B is taxable to him under section 811(d) of the Internal Revenue Code. If he is give...
The community property system has always been a thorn in the side of the federal tax structure. The ...
Decedent, an attorney, in 1925, at the age of sixty-nine, established two spendthrift trusts-one for...
Respondent, the owner of negotiable bonds, detached from them negotiable interest coupons shortly be...
I. The Lehman Doctrine Prior to the Technical Changes Act of 1949 II. The Lehman Doctrine Subsequent...
As is to be expected, many individuals desire to avoid the inclusion of all their property in their ...
A trust, established in 1908, reserved a power to the settlor to alter or amend the provisions of th...
Before the enactment of the 1924 gift tax statute, decedent created a trust for the benefit of named...
One of the most useful estate planning mechanisms for substantial estates is the irrevocable inter v...
In 1935, the donor created a trust for the benefit of seven children. The donor in her gift tax retu...
On May 14, 1919, decedent set up six trusts, appointing life estates with remainders over. Each trus...
In 1919 decedent transferred property in irrevocable trust, income to be paid to X for life and on X...
An inter vivas trust created by testator and property held jointly with his wife were included in hi...
In 1928, decedent established a trust giving his wife the income for her life, with a remainder to h...
In 1925 and 1926 decedent and his wife created two trusts, decedent contributing 80 per cent, and hi...
The gift tax is imposed on the transfer of property by gift. The term gift is not expressly defin...
The community property system has always been a thorn in the side of the federal tax structure. The ...
Decedent, an attorney, in 1925, at the age of sixty-nine, established two spendthrift trusts-one for...
Respondent, the owner of negotiable bonds, detached from them negotiable interest coupons shortly be...
I. The Lehman Doctrine Prior to the Technical Changes Act of 1949 II. The Lehman Doctrine Subsequent...
As is to be expected, many individuals desire to avoid the inclusion of all their property in their ...
A trust, established in 1908, reserved a power to the settlor to alter or amend the provisions of th...
Before the enactment of the 1924 gift tax statute, decedent created a trust for the benefit of named...
One of the most useful estate planning mechanisms for substantial estates is the irrevocable inter v...
In 1935, the donor created a trust for the benefit of seven children. The donor in her gift tax retu...
On May 14, 1919, decedent set up six trusts, appointing life estates with remainders over. Each trus...
In 1919 decedent transferred property in irrevocable trust, income to be paid to X for life and on X...
An inter vivas trust created by testator and property held jointly with his wife were included in hi...
In 1928, decedent established a trust giving his wife the income for her life, with a remainder to h...
In 1925 and 1926 decedent and his wife created two trusts, decedent contributing 80 per cent, and hi...
The gift tax is imposed on the transfer of property by gift. The term gift is not expressly defin...
The community property system has always been a thorn in the side of the federal tax structure. The ...
Decedent, an attorney, in 1925, at the age of sixty-nine, established two spendthrift trusts-one for...
Respondent, the owner of negotiable bonds, detached from them negotiable interest coupons shortly be...