Estate of Skinner v. United States
United States Court of Appeals for the Second Circuit
316 F.2d 517 (1963)
- Written by Eric Miller, JD
Facts
Maria Coxe Skinner established a trust that empowered the trustees, at their absolute discretion, to make payments from the trust assets to Skinner for her support and maintenance. Later, Skinner filed a gift-tax return in which she excluded the value of the trust assets because she believed that she had retained a life estate, or interest she held only during her life, in the corpus of the trust. The Internal Revenue Service (IRS) denied the exclusion on the ground that the trustees’ absolute discretion prevented the reservation of a life estate. Skinner received income from the trust for the rest of her life. Following Skinner’s death, the IRS commissioner—i.e., the United States government (defendant)—determined that the trust corpus was includable in her gross estate for federal tax purposes. This determination was based on Internal Revenue Code (IRC) § 811. [Editor’s Note: This provision of the tax code is now IRC § 2036.] Skinner’s estate (plaintiff) challenged this determination in federal district court, which found in favor of the government. Skinner’s estate appealed to the United States Court of Appeals for the Second Circuit.
Rule of Law
Issue
Holding and Reasoning (Biggs, C.J.)
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