Estate of Simonson v. Commissioner
United States Tax Court
Decedent in his will, established a trust, income payable to his son for life, remainder to a named charity. The trustees were given discretionary powers over the income and principal of the trust. Held, the discretionary powers did not constitute a power of indirect invasion of corpus and therefore the charitable remainder is deductible under sec. 2055, I.R.C. 1954.
1Opinion of the Court
Estate of Abraham Simonson, Deceased, Nathaniel Simonson and Ernest C. Geiger, Petitioners v. Commissioner of Internal Revenue, Respondent
Estate of Simonson v. Commissioner
Docket No. 941-69
United States Tax Court
59 T.C. 535; 1973 U.S. Tax Ct. LEXIS 186; 59 T.C. No. 52;
January 10, 1973, Filed
Decision will be entered under Rule 50.
Decedent in his will, established a trust, income payable to his son for life, remainder to a named charity. The trustees were given discretionary powers over the income and principal of the trust. Held, the discretionary powers did not constitute a power of indirect…
2Cases cited32 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Carrier v. . CarrierNew York Court of Appeals · 1919
- Blodget v. Delaney, CollectorCourt of Appeals for the First Circuit · 1953
- Estate of Ford v. CommissionerUnited States Tax Court · 1969
- Estate of Lillie MacMunn Stewart, Deceased, W. Alan Henderson v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1971
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