Estate of Levine v. Commissioner
United States Tax Court
Five trusts for minor grandchildren were created whereby the income interests during minority qualified as present interests for the annual exclusions solely by reason of sec. 2503(c). Upon attainment of age 21 the income was required to be paid at least annually to each grandchild for life.
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Five trusts for minor grandchildren were created whereby the income interests during minority qualified as present interests for the annual exclusions solely by reason of sec. 2503(c). Upon attainment of age 21 the income was required to be paid at least annually to each grandchild for life. Held, the income interests under these facts are to be treated in toto, i.e., as income interests for the life of the grandchild named in each trust, and not as separate components, and as such constitute single forms of property which are present interests for the purpose of the annual exclusions by…
1Opinion of the Court
Estate of David H. Levine, Deceased, Jacob Paul Levine and Richard L. Levine, Executors, Petitioners v. Commissioner of Internal Revenue, Respondent; Lillian K. Levine, Petitioner v. Commissioner of Internal Revenue, Respondent
Estate of Levine v. Commissioner
Docket Nos. 487-72, 488-72
United States Tax Court
63 T.C. 136; 1974 U.S. Tax Ct. LEXIS 23;
November 13, 1974, Filed
Decisions will be entered under Rule 155.
Five trusts for minor grandchildren were created whereby the income interests during minority qualified as present interests for the annual exclusions solely by reason of sec. 2503(c).…
Also in this document: Dissent.
2Cases cited12 opinions
- United States v. PelzerSupreme Court of the United States · 1941
- Fondren v. CommissionerSupreme Court of the United States · 1945
- Commissioner v. DisstonSupreme Court of the United States · 1945
- Weller v. CommissionerUnited States Tax Court · 1962
- Herr v. CommissionerUnited States Tax Court · 1961
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