Estate of Gilman v. Commissioner

65 T.C. 296, 1975 U.S. Tax Ct. LEXIS 37
CourtUnited States Tax Court
DecidedNovember 10, 1975
DocketDocket No. 2730-72
StatusPublished
Cited by31 cases

This text of 65 T.C. 296 (Estate of Gilman v. Commissioner) is published on Counsel Stack Legal Research, covering United States Tax Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Estate of Gilman v. Commissioner, 65 T.C. 296, 1975 U.S. Tax Ct. LEXIS 37 (tax 1975).

Opinions

OPINION

Under section 2036(a),2 property transferred by a decedent is included in his gross estate if, under the transfer, the decedent retained for his life or a period which did not in fact end before his death (1) the “enjoyment” of the property or (2) the right, either alone or in conjunction with any person, to designate the persons who shall enjoy the property or the income therefrom. Respondent relies upon these provisions to include the transferred Gilman Paper stock in decedent’s gross estate.3

Section 2036(a) reflects a “legislative policy of subjecting to tax all property which has been the subject of an incomplete inter vivos transfer.” United States v. O’Malley, 383 U.S. 627, 631 (1966). The policy is to include in a decedent’s gross estate transfers which are in substance testamentary, i.e., “transfers which leave the transferor a significant interest in or control over the property transferred during his lifetime.” United States v. Estate of Grace, 395 U.S. 316, 320 (1969).

As stated in Commissioner v. Estate of Church, 335 U.S. 632, 645(1949):

an estate tax cannot be avoided by any tmst transfer except by a bona fide transfer in which the settlor, absolutely, unequivocally, irrevocably, and without possible reservations, parts with all of his title and all of his possession and all of his enjoyment of the transferred property.

At the center of the present controversy is United States v. Byrum, 408 U.S. 125 (1972), the most recent Supreme Court pronouncement on the breadth and reach of section 2036(a). In that case, Byrum transferred stock in three unlisted corporations, in which he was the majority stockholder, to an irrevocable trust for the benefit of his children. He retained the right to vote the transferred stock, to veto any transfer by the trustee (a bank) of any stock, and to remove the trustee and appoint another corporate trustee as successor. The retained right to vote the transferred stock, together with the vote of the stock decedent owned at the time of his death, gave him a majority vote in each of the corporations. The Supreme Court held that the rights the decedent reserved in respect of the transferred stock did not constitute retained enjoyment thereof or the right to designate the person or persons who would enjoy the income therefrom, stating, inter alia, that (408 U.S. at 149):

The statutory language [of sec. 2036(a)] plainly contemplates retention of an attribute of the property transferred — such as a right to income, use of the property itself, or a power of appointment with respect either to income or principal.
Even if Byrum had transferred a majority of the stock, but had retained voting control,, he would not have retained “substantial present economic benefit,” * * * [Fn. ref. omitted.]

In support of its conclusion, the Court repeatedly emphasized the fiduciary duty of a majority shareholder not to misuse his power by promoting his personal interests at the expense of corporate interests and the fiduciary duty of the directors of a corporation not to play favorites among the shareholders but to promote the interests of the corporation as a whole. These duties so qualified the retained rights of the decedent that, the Court held, they were insufficient to cause inclusion of the stock in decedent’s gross estate under section 2036(a).

Petitioners contend that the Byrum case is dispositive of the instant one. Respondent seeks to distinguish the case on its facts. There are factual differences between the two cases, but we think that most of those differences add strength to petitioners’ case. We hold that decedent’s June 30, 1948, transfer of the Gilman Paper common stock in trust was a completed one and that the value of the stock is not includable in his gross estate.

1. Retention of Enjoyment

The Gilman Paper Co. stock may not be included in decedent’s gross estate under the portion of section 2036(a)(1) relied upon by respondent — that decedent retained the “enjoyment” of the stock — for two closely related reasons: (1) Decedent did not retain enjoyment of the stock “under” the transfer; and (2) the rights that he retained with respect to the stock did not constitute “enjoyment” within the meaning of that term as it is used in section 2036(a)( 1).

Section 2036(a)(1) applies only where the decedent has “retained” enjoyment “under” the “transfer.” This means that the enjoyment of the transferred property must be reserved “in connection with or as an incident to the transfer.” McNichol’s Estate v. Commissioner, 265 F.2d 667, 670 (3d Cir. 1959), affg. 29 T.C. 1179 (1958), cert. denied 361 U.S. 829 (1959). The section ápplies only where a prearrangement, embodied in an express or implied agreement, permits the transferor to enjoy the benefits of the property or its income. Estate of Roy D. Barlow, 55 T.C. 666, 670 (1971); Estate of Harry H. Beckwith, 55 T.C. 242, 247 (1970); Stephens, Maxfield, & Lind, Federal Estate and Gift Taxation, pp. 4-81 — 4-83 (3d ed.,1974); see also Fabian v. United States, 127 F.Supp. 726,728 (D; Conn. 1954). Thus, for example, the section does not apply where a husband transfers his interest in a residence to his wife and they continue to occupy it as the family home unless, by agreement, he reserves the right of occupancy as an incident to the transfer. Union Planters National Bank v. United States, 361 F.2d 662 (6th Cir. 1966); Estate of Binkley v. United States, 358 F.2d 639 (3d Cir. 1966); Estate of Allen D. Gutchess, 46 T.C. 554 (1966); Estate of Robert W. Wier, 17 T.C. 409, 422 (1951); Stephenson v. United States, 238 F.Supp. 660 (WD. Va. 1965); compare Estate of Emil Linderme, Sr., 52 T.C. 305 (1969).

The inquiry must be focused, therefore, on the. agreements made by the parties on June 30,. 1948, when the decedent’s Gilman Paper common stock was transferred to the trust. The question is whether there was an express or implied agreement at the time of the transfer that decedent would continue to enjoy that stock or that the right to enjoy the stock would later be conferred upon him.4 The evidence relating to events subsequent to the transfer is relevant only to the extent that it helps answer that question. .

In analyzing the evidence on that crucial question, it is important that the term “enjoyment” refers to the economic benefits obtainable from the transferred property. As stated in United States v. Byrum, 408 U.S.

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Bluebook (online)
65 T.C. 296, 1975 U.S. Tax Ct. LEXIS 37, Counsel Stack Legal Research, https://law.counselstack.com/opinion/estate-of-gilman-v-commissioner-tax-1975.