Quimbee logo
DMCA.com Protection Status
From our private database of 15,700+ case briefs...

Estate of Kohlsaat

United States Tax Court
T.C. Memo. 1997-212 (1997)

Facts

Lieselotte Kohlsaat created an irrevocable trust (the Estate), and transferred a commercial building into the trust. The trust designated Lieselotte’s two adult children as the two primary beneficiaries and sixteen of her grandchildren and great-grandchildren as contingent remainder beneficiaries. The trust gave the beneficiaries the right to demand an immediate distribution from the trust property during a 30-day period, up to the $10,000 annual gift tax exclusion amount for each beneficiary. The beneficiaries were notified of their rights to demand distributions. None of the beneficiaries exercised their right to demand a distribution. The petitioner, executor of the Estate, treated the interests of the sixteen contingent beneficiaries as qualifying for sixteen annual gift tax exclusions. The respondent, the Internal Revenue Service, denied the claimed annual gift tax exclusions, finding that the contingent beneficiaries did not have present interests in the trust.

Rule of Law

Issue

Holding and Reasoning (Swift, J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 97,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.

  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.

Here's why 333,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 15,700 briefs, keyed to 213 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Here's why 333,000 law students have relied on our case briefs:

  • Reliable - written by law professors and practitioners not other law students.
  • The right length and amount of information - includes the facts, issue, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your class - works on your mobile and tablet.
  • 15,700 briefs - keyed to 213 casebooks.
  • Uniform format for every case brief.
  • Written in plain English - not in legalese and not just repeating the court's language.
  • Massive library of related video lessons - and practice questions.
  • Top-notch customer support.