Estate of Levy v. Commissioner
United States Tax Court
Decedent and wife created trusts which had similar terms but under decedent's trust, wife had a special power of appointment over the trust corpus. Held, trusts are not interrelated and therefore not reciprocal within the meaning of United States v. Estate of Grace,395 U.S. 316 (1969); Estate of Bischoff v. Commissioner,69 T.C. 32 (1977); Krause v. Commissioner,57 T.C. 890 (1972).
1Opinion of the Court
ESTATE OF HERBERT LEVY, ILSE LEVY, EXECUTRIX, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Estate of Levy v. Commissioner
Docket No. 5833-81.
United States Tax Court
T.C. Memo 1983-453; 1983 Tax Ct. Memo LEXIS 335; 46 T.C.M. (CCH) 910; T.C.M. (RIA) 83453;
August 2, 1983.
Decedent and wife created trusts which had similar terms but under decedent's trust, wife had a special power of appointment over the trust corpus. Held, trusts are not interrelated and therefore not reciprocal within the meaning of United States v. Estate of Grace,395 U.S. 316 (1969); Estate of Bischoff v.…
2Cases cited9 opinions
- Estate of Spiegel v. CommissionerSupreme Court of the United States · 1949
- Lehman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1940
- United States v. Estate of GraceSupreme Court of the United States · 1969
- Estate of Bischoff v. CommissionerUnited States Tax Court · 1977
- Herman Glaser, Jr., as Administrator of the Estate of Herman Glaser, Sr., Deceased v. United StatesCourt of Appeals for the Seventh Circuit · 1962
4 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- In re St. Clair Trust ReformationSupreme Court of Kansas · 2020