Estate of Humbert v. Commissioner
United States Tax Court
On Sept. 5, 1969, decedents made inter vivos transfers to separate, identical trusts, reserving the right to receive specified monthly payments during their lives. After their deaths, "part or all of the principal" was to be paid to Martha Irene Humbert "or applied for her benefit but only in such amounts as the Trustee deems necessary in its discretion." On Martha's death, the principal of the two trusts was to be paid to designated charities.
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On Sept. 5, 1969, decedents made inter vivos transfers to separate, identical trusts, reserving the right to receive specified monthly payments during their lives. After their deaths, "part or all of the principal" was to be paid to Martha Irene Humbert "or applied for her benefit but only in such amounts as the Trustee deems necessary in its discretion." On Martha's death, the principal of the two trusts was to be paid to designated charities. On Nov. 3, 1969, decedents executed wills leaving the residue of their respective estates to their separate trusts. Both of the decedents died in…
1Opinion of the Court
OPINION
Featherston, Judge:
Respondent determined the following deficiencies in petitioners’ Federal estate tax:
Petitioner Deficiency
Estate of Virginia I. Humbert
docket No. 7147-75.$14,256.29
Estate of Ralph H. Humbert
docket No. 7148-75. 196,885.60
The sole issue1 for decision is whether petitioners are entitled to deductions under section 2055(a)2 for charitable remainder interests in property transferred in trust by decedents Virginia I. Humbert and Ralph H. Humbert.
All the facts are stipulated.
Virginia I. Humbert (hereinafter Virginia) died on January 25, 1971, and Ralph H. Humbert (Ralph),…
2Cases cited12 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Ithaca Trust Co. v. United StatesSupreme Court of the United States · 1929
- Merchants Nat. Bank of Boston v. CommissionerSupreme Court of the United States · 1943
- Taylor v. CommissionerUnited States Tax Court · 1977
- Newton Trust Co. v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1947
7 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Estate of Crafts v. CommissionerUnited States Tax Court · 1980
- Oetting v. United StatesDistrict Court, E.D. Missouri · 1982
- Estate of Crafts v. CommissionerUnited States Tax Court · 1980
- Estate of Dumesnil v. CommissionerUnited States Tax Court · 1982
- Estate of Humbert v. CommissionerUnited States Tax Court · 1978
2 more not listed; retrieve them via the Exa API.