Edwards v. Commissioner
United States Tax Court
A widow settled her statutory claim against her husband's estate by releasing it in return for a promise of monthly payments from the income of an irrevocable inter vivos spendthrift trust set up by her husband. His son, the trustee and life income beneficiary, agreed to pay her if the trust income became insufficient. The trust income has greatly exceeded the payments to her. The trust is to terminate at the death of the son.
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A widow settled her statutory claim against her husband's estate by releasing it in return for a promise of monthly payments from the income of an irrevocable inter vivos spendthrift trust set up by her husband. His son, the trustee and life income beneficiary, agreed to pay her if the trust income became insufficient. The trust income has greatly exceeded the payments to her. The trust is to terminate at the death of the son. Held: 1. The monthly payments are an inheritance of income from property and not excludible from income under sec. 22(b)(3), I.R.C. 1939, or sec. 102(b), I.R.C. 1954.…
1Opinion of the Court
James F. Edwards and Joan C. Edwards, Petitioners, v. Commissioner of Internal Revenue, Respondent. Esther S. Edwards, Petitioner, v. Commissioner of Internal Revenue, Respondent
Edwards v. Commissioner
Docket Nos. 83598, 86533
United States Tax Court
37 T.C. 1107; 1962 U.S. Tax Ct. LEXIS 171;
March 19, 1962, Filed
Decisions will be entered under Rule 50.
A widow settled her statutory claim against her husband's estate by releasing it in return for a promise of monthly payments from the income of an irrevocable inter vivos spendthrift trust set up by her husband. His son, the trustee and life income…
2Cases cited7 opinions
- Lyeth v. HoeySupreme Court of the United States · 1938
- Griffith v. CommissionerUnited States Tax Court · 1961
- Doris B. Harte and Stanley J. Harte v. United StatesCourt of Appeals for the Second Circuit · 1958
- Cadwalader v. CommissionerUnited States Board of Tax Appeals · 1933
- Williams v. CommissionerUnited States Tax Court · 1961
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