From our private database of 35,600+ case briefs...
Jennings v. Smith
United States Court of Appeals for the Second Circuit
161 F.2d 74 (1947)
Oliver Jennings transferred property into two irrevocable trusts, one for each of his two sons. Jennings named himself and his sons as the trustees for both trusts and paid gift taxes on these permanent transfers. Under the trusts’ terms, if either son needed money to maintain his family’s usual lifestyle, the trustees were allowed to distribute trust income to that son. Otherwise, the trustees were obligated to accumulate the income. The trustees were also allowed to distribute a trust’s principal to a son if the son needed the money to pay extraordinary medical expenses, handle financial misfortune, or buy a residence. Otherwise, the trustees could not distribute the trusts’ principals. When Jennings died, the federal government (defendant) and Jennings’s estate (plaintiff) disputed several estate-tax matters. Ultimately, the only remaining issue was the government’s claim that the principals and incomes from the two trusts were taxable parts of Jennings’s gross estate. The district court ruled that Jennings had retained the right to control the trusts’ principals and incomes through his trustee power to distribute the principals or incomes and, therefore, that both items were taxable parts of the gross estate. The estate appealed to the Second Circuit.
Rule of Law
Holding and Reasoning (Swan, J.)
What to do next…
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 618,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.Unlock this case briefRead our student testimonials
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.Learn about our approachRead more about Quimbee
Here's why 618,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 35,600 briefs, keyed to 984 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.