Rand Trust v. Commissioner
United States Tax Court
Where the will and trust indenture provided for the subdivision of each family group's share into separate parts, contained language in the various provisions evidencing intention to create separate trusts, and used the plural or singular form where appropriate, and where the trusts as created were in most respects independent of each other, held, the instruments provided for separate trusts within each family group for the respective living and after-born grandchildren and…
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Where the will and trust indenture provided for the subdivision of each family group's share into separate parts, contained language in the various provisions evidencing intention to create separate trusts, and used the plural or singular form where appropriate, and where the trusts as created were in most respects independent of each other, held, the instruments provided for separate trusts within each family group for the respective living and after-born grandchildren and grandnieces or grandnephews. McHarg v. Fitzpatrick, 210 F. 2d 792 (C.A. 2), explained and followed.
1Opinion of the Court
Frank C. Rand Trust, U/W for the benefit of the Henry H. Rand Family Group, Norfleet H. Rand, Henry H. Rand and Mercantile Trust Company, Trustees, et al. 1 v. Commissioner.
Rand Trust v. Commissioner
Docket Nos. 72381-72385; 76434-76441.
United States Tax Court
T.C. Memo 1960-216; 1960 Tax Ct. Memo LEXIS 73; 19 T.C.M. (CCH) 1205; T.C.M. (RIA) 60216;
October 11, 1960
Where the will and trust indenture provided for the subdivision of each family group's share into separate parts, contained language in the various provisions evidencing intention to create separate trusts, and used the plural or…
2Cases cited22 opinions
- Olender v. United StatesCourt of Appeals for the Ninth Circuit · 1954
- Gallagher v. SmithCourt of Appeals for the Third Circuit · 1955
- US Trust Co. v. Commissioner of Internal RevenueSupreme Court of the United States · 1936
- Huntington Nat. Bank v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1937
- Krause v. Jeannette Investment Co.Supreme Court of Missouri · 1933
17 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- North Carolina National Bank v. GoodeSupreme Court of North Carolina · 1979
- Commercial Bank at Winter Park v. United StatesCourt of Appeals for the Fifth Circuit · 1971
- The Commercial Bank At Winter Park v. United StatesCourt of Appeals for the Fifth Circuit · 1971