Legal Opinion

Leonard v. Commissioner

United States Tax Court

Decided April 30, 1945No. Docket Nos. 555, 556, 578, 577, 579Published

In 1938, petitioners, husband and wife, transferred community property to the husband as trustee for their three minor daughters. The trusts were irrevocable and for long terms.

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In 1938, petitioners, husband and wife, transferred community property to the husband as trustee for their three minor daughters. The trusts were irrevocable and for long terms. Only in the event the grantors, as parents, were unable to support the beneficiaries could the trustee in his sole discretion distribute any income prior to the beneficiary attaining the age of 21. Distribution of certain percentages of the trust estate was mandatory when beneficiary attained the ages of 21 and 30, and the trustee in his discretion could distribute a certain part of the trust estate when beneficiary…

1Opinion of the Court

J. M. Leonard, Petitioner, v. Commissioner of Internal Revenue, Respondent. Mary Leonard (Mrs. J. M. Leonard), Petitioner, v. Commissioner of Internal Revenue, Respondent. Mary Leonard Trust #1, J. M. Leonard, Trustee, Petitioner, v. Commissioner of Internal Revenue, Respondent. Miranda Leonard Trust #1, J. M. Leonard, Trustee, Petitioner, v. Commissioner of Internal Revenue, Respondent. Martha Leonard Trust #1, J. M. Leonard, Trustee, Petitioner, v. Commissioner of Internal Revenue, Respondent

Leonard v. Commissioner

Docket Nos. 555, 556, 578, 577, 579

United States Tax Court

4 T.C. 1271; 1945…

2Cases cited8 opinions

  1. Helvering v. CliffordSupreme Court of the United States · 1940
  2. Helvering v. FullerSupreme Court of the United States · 1940
  3. Cartinhour v. CommissionerUnited States Tax Court · 1944
  4. Lowenstein v. CommissionerUnited States Tax Court · 1944
  5. Stockstrom v. CommissionerUnited States Tax Court · 1944

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