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Estate of Sanford v. Commissioner

308 U.S. 39 (1939)

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Estate of Sanford v. Commissioner

United States Supreme Court

308 U.S. 39 (1939)

Facts

About a decade before Congress first established the gift tax, Mr. Sanford made a gift in trust for the benefit of several named beneficiaries. Sanford originally retained the power both to revoke the trust and to alter the beneficiaries. Several years later, Sanford formally relinquished his power to revoke the trust but retained the power to substitute new beneficiaries other than himself. Congress then enacted the gift-tax statute. After the passage of the statute, Sanford relinquished all remaining powers he had to modify the trust, including the power to alter the beneficiaries. Sanford died several years later, and his affairs came to be managed by his estate (plaintiff). The Internal Revenue Service (IRS) (defendant) determined that Sanford’s gift had not been completed until Sanford had relinquished all of his power to modify the trust. Because Sanford did not do so until after Congress had enacted the gift tax, the IRS reasoned, the gift was subject to the gift tax. Accordingly, the IRS assessed a deficiency against Sanford’s estate. The estate petitioned the board of tax appeals, which upheld the IRS’s determination. The court of appeals affirmed, and the United States Supreme Court granted certiorari.

Rule of Law

Issue

Holding and Reasoning (Stone, J.)

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