# Glen v. Commissioner

> United States Tax Court · January 4, 1966 · 45 T.C. 323

URL: https://www.frixlaw.com/law-library/cases/4480298

## Case

- **Full name:** Estate of Robert Rodger Glen, Claire Huntington Glen v. Commissioner of Internal Revenue, Respondent Morgan Guaranty Trust Company of New York, Trustee Under Instrument Created by Robert Rodger Glen v. Commissioner of Internal Revenue
- **Court:** United States Tax Court
- **Decided:** January 4, 1966
- **Citations:** 45 T.C. 323; 1966 U.S. Tax Ct. LEXIS 152
- **Precedential status:** Published
- **Opinion:** Dissent by Drennen
- **Judges:** Hoyt,Simpson,Raum,Drennen,Tannenwald
- **Cited by:** 31 later opinions in the Frix Law Library

## Citator (automated)

- No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases.
- Full citator and citing cases: https://www.frixlaw.com/law-library/cases/4480298

## Opinion text

Drennen, J., dissenting: 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,

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/4480298. Public record. Not legal advice.