e., he had "paid for and brought about" the transfer of property by Allan Lehman in trust for the benefit of Harold Lehman and the latter's issue. 100-101) that Harold, by transferring his share of the stocks and bonds in trust for the benefit of Allan and the latter's issue, had "paid for and brought about" the transfer by Allan of his share of the stocks and bonds in trust for the benefit of Harold and Harold's issue and, therefore, that Allan's transfer was in substance a transfer by Harold, so as to make the property so transferred part of Harold's taxable estate.Īccording to one line of cases, the crucial factor in the Lehman case was that, under the agreed facts, Harold Lehman had furnished consideration for - i. This question was answered in the affirmative. Harold later died, and the court was called upon to decide whether trust property transferred by Allan was taxable as part of Harold's estate. Similarly, the income from the trust property transferred by Allan was to be paid to Harold for his life, with the remainder to Harold's issue, and Harold had the right to withdraw up to $150,000 of the principal. The income from the trust property transferred by Harold was to be paid to Allan for his life, with the remainder to Allan's issue, and Allan had the right to withdraw not to exceed $150,000 of the principal. Harold agreed to transfer his share in trust for Allen and the latter's issue, in consideration of Allan transferring his share in trust for Harold and Harold's issue, and trusts were created in accordance with the agreement. Lehman, owned equal shares in certain stocks and bonds. According to the stipulation, two brothers, Harold M. The facts in the Lehman case were stipulated by the parties.
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