Brown v. Commissioner
United States Board of Tax Appeals
1. ESTATE TAX. - The amount paid to a trustee for management of a trust estate created by decedent during his lifetime is held to constitute a reduction of the trust property in determining the value at which it is to be included in the gross estate. 2. Id. - Amounts paid by the trustees out of the trust fund for the erection of a church, and to other institutions, under a power conferred upon them in the trust instrument to distribute the residue of the trust property in…
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1. ESTATE TAX. - The amount paid to a trustee for management of a trust estate created by decedent during his lifetime is held to constitute a reduction of the trust property in determining the value at which it is to be included in the gross estate. 2. Id. - Amounts paid by the trustees out of the trust fund for the erection of a church, and to other institutions, under a power conferred upon them in the trust instrument to distribute the residue of the trust property in such way and at such time or times as they, in their unrestricted judgment may deem best, are not deductible under section…
1Opinion of the Court
*51OPINION.
Aettndell :
Petitioner claims as a deduction from decedent’s gross estate the sum of $25,000 paid to the Provident Trust Co., Trustee, under the trust agreement executed by the decedent before his death. The deduction of this amount is sought either on the ground that it is an administration expense or a claim against the estate.
As set forth in the findings of fact, the decedent some time prior to his death created a trust estate and conveyed to it property having a value of more than $2,000,000. The Provident Trust Co. was the custodian of these funds and one of the trustees under the…
2Cases cited12 opinions
- Lederer v. StocktonSupreme Court of the United States · 1922
- Wheeler v. SmithSupreme Court of the United States · 1850
- Estate of Beatty v. Western College of ToledoIllinois Supreme Court · 1898
- Hynes v. WhiteCalifornia Court of Appeal · 1920
- Dulles's EstateSupreme Court of Pennsylvania · 1907
7 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- Brown v. CommissionerUnited States Board of Tax Appeals · 1930
- St. Louis Union Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1931