Estate of Spiegel et al. v. Commissioner of Internal Revenue (335 U.S. 701)
U.S. Supreme Court · decided January 17, 1949 · Supreme Court Database (Spaeth)
- Citation
- 335 U.S. 701 · 69 S. Ct. 301
- Docket
- No. 3
- Argued
- October 24, 1947; reargued October 11, 1948
- Decided
- January 17, 1949
- Term
- October Term 1948
- Vote
- 6–3
- Majority author
- Justice Black
- Issue area
- Federal Taxation
- Disposition
- Affirmed
- Outcome
- Petitioning party lost
- Ideological direction
- Liberal
How the Justices voted
- Majority
- Chief Justice Vinson, Justice Douglas, Justice Black (wrote), Justice Rutledge, Justice Murphy
- Concurring in the judgment
- Justice Reed (wrote)
- Dissenting
- Justice Burton (wrote), Justice R. H. Jackson, Justice Frankfurter (wrote)
Opinion excerpt
Mr. Justice Black delivered the opinion of the Court. This is a federal estate tax controversy. Here, as in Commissioner v. Church, ante, p. 632, we granted cer-tiorari to consider questions dependent upon the meaning and application of a provision of § 811 (c) of the Internal Revenue Code. 47 Stat. 169, 279, as amended, 26 U. S. C. §811 (c). The particular provision requires including in a decedent’s gross estate the value at his death of all property “To the extent of any interest therein of which the decedent has at any time made a transfer, by trust or otherwise . . . intended to take effect in possession or enjoyment at or after his death In 1920 Sidney M. Spiegel, a resident of Illinois, made a transfer by trust of certain stocks to himself and another. He died in 1940. During his life the trust income was to be divided among his three children; if they did not survive him, to any of their surviving children. On his death the trust provided that the corpus was to be distributed in the same manner. But no provision was made for distribution of the corpus and its accumulated income should Mr. Spiegel survive all of his children and grandchildren. For this reason the Government has contended that under controlling state law the property would have reverted to Mr. Spiegel had he survived his designated beneficiaries. The value of the corpus of this trust was not included in…
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