Legal Opinion

Estate of Robinson v. Commissioner

United States Tax Court

Decided December 2, 1993No. Docket Nos. 14599-90, 939-91Published

D's late husband bequeathed his estate to a marital trust, for the benefit of D, and a residuary trust, for the benefit of his children and grandchildren. The marital trust was to be funded by one-half of the assets of the estate and the residuary trust was to be funded by the remaining assets of the estate. The will gave D a testamentary power of appointment over the assets of the marital trust.

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D's late husband bequeathed his estate to a marital trust, for the benefit of D, and a residuary trust, for the benefit of his children and grandchildren. The marital trust was to be funded by one-half of the assets of the estate and the residuary trust was to be funded by the remaining assets of the estate. The will gave D a testamentary power of appointment over the assets of the marital trust. If D failed to exercise her testamentary power of appointment, the assets of the marital trust were to pass to the beneficiaries of the residuary trust. a family dispute ensued, and neither of the…

1Opinion of the Court

Estate of Inez T. Robinson, Deceased, Tom Ed Robinson and Ralph E. Robinson, Co-Executors, Petitioner v. Commissioner of Internal Revenue, Respondent

Estate of Robinson v. Commissioner

Docket Nos. 14599-90, 939-91

United States Tax Court

101 T.C. 499; 1993 U.S. Tax Ct. LEXIS 74; 101 T.C. No. 33;

December 2, 1993, Filed

Decisions will be entered under Rule 155.

D's late husband bequeathed his estate to a marital trust, for the benefit of D, and a residuary trust, for the benefit of his children and grandchildren. The marital trust was to be funded by one-half of the assets of the estate and the…

2Cases cited21 opinions

  1. Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
  2. Aquilino v. United StatesSupreme Court of the United States · 1960
  3. United States v. PelzerSupreme Court of the United States · 1941
  4. Commissioner v. DanielsonCourt of Appeals for the Third Circuit · 1967
  5. Danielson v. CommissionerUnited States Tax Court · 1965

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