Legal Opinion

Grimm v. Commissioner

United States Tax Court

Decided February 10, 1965No. Docket No. 337-63PublishedCited by 4 opinions

Held, petitioner, the sole trustee and sole income beneficiary of a trust, is not liable under section 6903, I.R.C. 1954, for estate tax deficiency assessed against the estate of the remainderman. Estate of Nathan P. Cutler, Jr., 5 T.C. 1304, 1315-1316, distinguished.

1Opinion of the Court

opinion

Eaum, Judge:

The Commissioner determined that petitioner is personally liable for the payment of $193,758.65 estate tax deficiency plus interest in respect of the estate of Josepliine D. Robinson,1 who died in 1957, a resident of Florida.

Petitioner is not a transferee of the decedent or her estate; he is not a beneficiary of her estate; he is neither a trustee nor beneficiary of any trust established by the decedent by deed or will; and he is neither an executor nor an administrator in respect of her estate. However, petitioner is the sole trustee and sole life beneficiary of a trust in…

2Cases cited8 opinions

  1. Newton Trust Co. v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1947
  2. Fletcher Trust Co. v. COMMISSIONER OF INT. REVENUECourt of Appeals for the Seventh Circuit · 1944
  3. Fletcher Trust Co. v. CommissionerUnited States Tax Court · 1943
  4. Matter of Reed v. BrowneNew York Court of Appeals · 1946
  5. Cutler v. CommissionerUnited States Tax Court · 1945

3 more not listed; retrieve them via the Exa API.

3Cited by4 opinions

  1. Polkinhorn v. United StatesDistrict Court, District of Columbia · 1970
  2. Polkinhorn v. United StatesCourt of Appeals for the D.C. Circuit · 1970
  3. Estate of Berger v. CommissionerUnited States Tax Court · 1990
  4. Grimm v. CommissionerUnited States Tax Court · 1965

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