Estate of Hutchinson v. Commissioner
United States Tax Court
Decedent established four testamentary trusts, A, B, C, and D, for the benefit primarily of a son, daughter, and numerous other relatives and descendants, both living and unborn, with remainders over, through trustee, to the Board of Regents of the State of Iowa. The trust corpus of each trust was subject to invasion to meet the required distributions to beneficiaries. The overall life of the trusts was estimated at about 100 years.
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Decedent established four testamentary trusts, A, B, C, and D, for the benefit primarily of a son, daughter, and numerous other relatives and descendants, both living and unborn, with remainders over, through trustee, to the Board of Regents of the State of Iowa. The trust corpus of each trust was subject to invasion to meet the required distributions to beneficiaries. The overall life of the trusts was estimated at about 100 years. Held: That there was no reasonable certainty of a gift to charity of any ascertainable amount at the date of decedent's death. Therefore, the claimed deduction is…
1Opinion of the Court
Estate of Elizabeth Annis Hutchinson, Charles H. McConnell, Executor, Petitioner v. Commissioner of Internal Revenue, Respondent
Estate of Hutchinson v. Commissioner
Docket No. 1112-67
United States Tax Court
51 T.C. 874; 1969 U.S. Tax Ct. LEXIS 183;
February 27, 1969, Filed
Decision will be entered under Rule 50.
Decedent established four testamentary trusts, A, B, C, and D, for the benefit primarily of a son, daughter, and numerous other relatives and descendants, both living and unborn, with remainders over, through trustee, to the Board of Regents of the State of Iowa. The trust corpus of each…
2Cases cited10 opinions
- Ithaca Trust Co. v. United StatesSupreme Court of the United States · 1929
- Henslee v. Union Planters National Bank & Trust Co.Supreme Court of the United States · 1949
- Merchants Nat. Bank of Boston v. CommissionerSupreme Court of the United States · 1943
- Humes v. United StatesSupreme Court of the United States · 1928
- Commissioner v. Estate of SternbergerSupreme Court of the United States · 1955
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