Pingree v. Commissioner
United States Board of Tax Appeals
INCOME - TRUST - TAXABLE TO GRANTOR. - Where the petitioner placed property in trust, to be divided equally and the income from one-half to be paid to her mother for life, but retained the power to appoint by will the remainder after the life estate and the right to withdraw up to a certain amount with the consent of the mother, the income from the one-half set up for the benefit of the mother is not taxable to the petitioner.
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INCOME - TRUST - TAXABLE TO GRANTOR. - Where the petitioner placed property in trust, to be divided equally and the income from one-half to be paid to her mother for life, but retained the power to appoint by will the remainder after the life estate and the right to withdraw up to a certain amount with the consent of the mother, the income from the one-half set up for the benefit of the mother is not taxable to the petitioner. Sections 166, 167, and 22(a) of the Revenue Act of 1936 have no application.
1Opinion of the Court
MARY W. PINGREE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Pingree v. Commissioner
Docket No. 104858.
United States Board of Tax Appeals
45 B.T.A. 32; 1941 BTA LEXIS 1184;
September 5, 1941, Promulgated
INCOME - TRUST - TAXABLE TO GRANTOR. - Where the petitioner placed property in trust, to be divided equally and the income from one-half to be paid to her mother for life, but retained the power to appoint by will the remainder after the life estate and the right to withdraw up to a certain amount with the consent of the mother, the income from the one-half set up for the benefit…
2Cases cited1 opinion
- Pingree v. CommissionerUnited States Board of Tax Appeals · 1941