¶1dissenting: I agree with the first part of Judge Tan-nenwald’s dissent concerning the question of consideration, but I am not certain that he reaches the correct conclusion with respect to allocation of the consideration and the amount to be excluded from the gross estate. I am inclined to take the view that $190,131 should be excluded because that is the amount of the consideration received by decedent for the interest transferred to his wife and the consideration she paid for what she received for herself. Of course, this means I also disagree with the allocation made in the majority opinion,
45 T.C. 323
Glen v. Commissioner
Decided January 4, 1966
United States Tax Court · decided 1966-01-04
Decedent entered into a property settlement agreement with his then wife, Jane, prior to divorce, in which the wife relinquished all of her rights against decedent… Held: The transfers in trust were made for adequate consideration to the extent of the value of Jane's right upon divorce to one-third of decedent's personal property which she relinquished, and to that extent the property transferred is therefore not includable in decedent's gross estate under section 2036.
Good law ✅— No negative treatment on recordhow we know
Decisions will be entered under Rule 50 · Decided 1966-01-04
How this case has been cited
Cited by 29 later decisions — most recently June 1996 · most notably Estate of Waters v. Commissioner of the Internal Revenue Service (1995), Estate of Whitlock v. Commissioner (1972)
7 federal appellate · 1 state decisions
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
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