Legal Opinion

Wooster v. Commissioner

United States Tax Court

Decided October 23, 1947No. Docket No. 12425Published

1. Decedent's father in 1916 created a trust for her and two of her sisters, providing general powers of appointment over both income and corpus. The trust provided that, in case a sister died without exercising the power and without surviving issue, the survivor or survivors took the powers. One sister died without surviving issue and without exercising the power, whereupon decedent and her sister Ruth were owners of a half interest each in the powers.

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1. Decedent's father in 1916 created a trust for her and two of her sisters, providing general powers of appointment over both income and corpus. The trust provided that, in case a sister died without exercising the power and without surviving issue, the survivor or survivors took the powers. One sister died without surviving issue and without exercising the power, whereupon decedent and her sister Ruth were owners of a half interest each in the powers. Decedent by will provided that, in case her sister Ruth should survive her, one-half of decedent's share of trust principal and income should…

1Opinion of the Court

Estate of Mabel Wooster, the Union & New Haven Trust Company, Executor, Petitioner, v. Commissioner of Internal Revenue, Respondent

Wooster v. Commissioner

Docket No. 12425

United States Tax Court

9 T.C. 742; 1947 U.S. Tax Ct. LEXIS 56;

October 23, 1947, Promulgated

Decision will be entered under Rule 50.

1. Decedent's father in 1916 created a trust for her and two of her sisters, providing general powers of appointment over both income and corpus. The trust provided that, in case a sister died without exercising the power and without surviving issue, the survivor or survivors took the powers. One…

2Cases cited9 opinions

  1. Freuler v. HelveringSupreme Court of the United States · 1934
  2. Riggs v. Del DragoSupreme Court of the United States · 1942
  3. Estate of Rogers v. CommissionerSupreme Court of the United States · 1943
  4. McGee v. VandeventerIllinois Supreme Court · 1927
  5. Bradford v. AndrewIllinois Supreme Court · 1923

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