ALLEN

v.

COMMISSIONER OF INTERNAL REVENUE

Citator

Cited By

• Gaylord v. Commissioner OF Internal Revenue (two cases), 153 F.2d 408 (9th Cir. 1946)
  …, it is clear that the existence of a power in the grantor to revoke or revest title in himself is to be determined from state law. Cf. Howard v. United States, 5 Cir., 125 F. 2d 986. See also Com’r v. Allen, 3 Cir., 108 F. 2d 961, certiorari denied 309 U.S. 680, 60 S.Ct. 718, 84 L.Ed. 1023; Hughes v. Com’r, 9 Cir., 104 F. 2d 144, 147; Section 2280 Civil Code of California, note 2. See also comments on this Code section in “Studies in Federal Taxation”, Third Series, Paul, p. 190. The trust instrument here…
• In re Roney. Roney v. Fed. Land Bank of Louisville, 119 F.2d 989 (7th Cir. 1941)
  …1, 2, 52 Stat. 84, approved March 4, 1938, 11 U.S.C. § 203(c), the Congress by statute extended the duration of the moratorium until March 4, 1940. We said in Lowman v. Federal Land Bank of Louisville, 7 Cir., 107 F. 2d 540, 543, certiorari denied, 309 U.S. 680, 60 S.Ct. 724, 84 L.Ed. 1024, April 1, 1940, “the enactment in question is an amendment to the provision of the original act which limited the time for the filing of petitions under the act to five years after March 3, 1933. By the act of March 4, 1…
• Dodge v. United States, 413 F.2d 1239 (5th Cir. 1969)
  …s ruled incomplete when made because the grantor then reserved a power of revocation but was held to be consummated in a later year when that power was can-celled. Commissioner of Internal Revenue v. Allen, 108 F. 2d 961 (3 Cir. 1939), cert. denied, 309 U.S. 680, 60 S.Ct. 718, 84 L.Ed. 1023 (1940), applied the same principle to a gift by a minor which was revocable under state law after attaining twenty-one. See, also, § 25.2511-2(c) of the Gift Tax Regulations (“A gift is incomplete in every instance in wh…