Spruance v. Commissioner

60 T.C. 141 (1973)

From our private database of 46,000+ case briefs, written and edited by humans—never with AI.

Spruance v. Commissioner

United States Tax Court
60 T.C. 141 (1973)

Facts

Preston Spruance (plaintiff) and Margaret Spruance entered into two agreements that, read together, operated as the couple’s property-settlement agreement for their divorce. The combined divorce agreement provided that Preston would transfer approximately $1 million in stock into a trust for Margaret and the couple’s four children. The trust’s income would be used to provide support and maintenance for Margaret and the three children who were still minors. After Margaret and Preston both died, the trust’s remainder would be distributed to all four children. The commissioner of Internal Revenue (defendant) determined that $450,000 of Preston’s $1 million transfer was not attributable to the support and maintenance payments. Rather, this amount was a direct property transfer to the four children, who would receive the property outright when their parents died. Preston did not contest the calculations. However, Preston petitioned for a determination that the entire $1 million transfer was not a gift because it was made pursuant to a divorce agreement.

Rule of Law

Issue

Holding and Reasoning (Dawson, 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 742,000 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
  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.

    Learn about our approachRead more about Quimbee

Here's why 742,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 46,000 briefs, keyed to 986 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.

Access this case brief for FREE

With a 7-day free trial membership
Here's why 742,000 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
  • 46,000 briefs - keyed to 986 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

Access this case brief for FREE

With a 7-day free trial membership