Legal Opinion

Bishop v. Commissioner

United States Tax Court

Decided February 28, 1945No. Docket Nos. 692, 3124, 693, 3123Published

Petitioners, husband and wife, simultaneously created trusts of approximately equal value for each other for life with remainder over; each life beneficiary was given a general testamentary power of appointment of the corpus in lieu of the remainders; income was distributable at the discretion of the corporation trustee, whom the life beneficiary was given the power to change at will from time to time to any other corporate trustee; and prior to and outside the indentures,…

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Petitioners, husband and wife, simultaneously created trusts of approximately equal value for each other for life with remainder over; each life beneficiary was given a general testamentary power of appointment of the corpus in lieu of the remainders; income was distributable at the discretion of the corporation trustee, whom the life beneficiary was given the power to change at will from time to time to any other corporate trustee; and prior to and outside the indentures, the trustee agreed with petitioners to pay the income at the request of the life beneficiary. Held, the income of each…

1Opinion of the Court

Edward E. Bishop, Petitioner, v. Commissioner of Internal Revenue, Respondent. Lillian H. Bishop, Petitioner, v. Commissioner of Internal Revenue, Respondent

Bishop v. Commissioner

Docket Nos. 692, 3124, 693, 3123

United States Tax Court

4 T.C. 862; 1945 U.S. Tax Ct. LEXIS 214;

February 28, 1945, Promulgated

Decisions will be entered under Rule 50.

Petitioners, husband and wife, simultaneously created trusts of approximately equal value for each other for life with remainder over; each life beneficiary was given a general testamentary power of appointment of the corpus in lieu of the remainders;…

2Cases cited12 opinions

  1. Helvering v. CliffordSupreme Court of the United States · 1940
  2. Lucas v. EarlSupreme Court of the United States · 1930
  3. Helvering v. HorstSupreme Court of the United States · 1940
  4. Corliss v. BowersSupreme Court of the United States · 1930
  5. Reinecke v. Northern Trust Co.Supreme Court of the United States · 1929

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