Estate of Edmonds v. Commissioner
United States Tax Court
1. In 1960, decedent established an inter vivos irrevocable pour-over family trust to pay fixed annuities to certain beneficiaries. The trust described one method by which decedent could establish additional annuities and gave the trustee certain administrative powers if this method was utilized.
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1. In 1960, decedent established an inter vivos irrevocable pour-over family trust to pay fixed annuities to certain beneficiaries. The trust described one method by which decedent could establish additional annuities and gave the trustee certain administrative powers if this method was utilized. Decedent subsequently followed this method and established three supplemental trusts, funded separately, to provide additional annuities to some of the beneficiaries of the family trust. Under the terms of the supplemental trust indentures, decedent reserved the power to terminate these trusts; upon…
1Opinion of the Court
Wilbur, Judge:
Respondent determined a deficiency of $826,270.87 in petitioner’s estate tax. Concessions having been made by the parties, the issues remaining for decision are:(1) Whether the value of the portion of the principal of an inter vivos trust created by an indenture dated March 25, 1960, which is attributable to contributions by the decedent is includable in the decedent’s gross estate;(2) Whether the value of the portion of the principal of the aforementioned trust which is attributable to contributions by persons other than the decedent is includable in the decedent’s gross…
2Cases cited23 opinions
- Morgan v. CommissionerSupreme Court of the United States · 1940
- Helvering v. StuartSupreme Court of the United States · 1942
- Commissioner of Internal Revenue v. Chase Nat. BankCourt of Appeals for the Second Circuit · 1936
- Elizabeth Joan Allen and Alice Edna Stuhmer, Individually and as Executrices of the Estate of Chester A. Allen, Deceased v. United StatesCourt of Appeals for the Second Circuit · 1966
- In re DoelgerAppellate Division of the Supreme Court of the State of New York · 1938
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3Cited by3 opinions
- The First National Bank of Denver, Trustee of the Barry M. Sullivan Trust v. United StatesCourt of Appeals for the First Circuit · 1981
- Estate of Shapiro v. CommissionerUnited States Tax Court · 1993
- Estate of Edmonds v. CommissionerUnited States Tax Court · 1979