Estate of Clack v. Commissioner
United States Tax Court
Decedent's will gave his surviving spouse an income interest in certain marital trust property but provided that if decedent's coexecutors did not elect to treat the property as "qualified terminable interest property" (QTIP) within the meaning of sec. 2056(b)(7), I.R.C., such property would instead be administered under the terms of a nonmarital family trust. Held: The marital trust property is QTIP within the meaning of sec. 2056(b)(7), I.R.C.
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Decedent's will gave his surviving spouse an income interest in certain marital trust property but provided that if decedent's coexecutors did not elect to treat the property as "qualified terminable interest property" (QTIP) within the meaning of sec. 2056(b)(7), I.R.C., such property would instead be administered under the terms of a nonmarital family trust. Held: The marital trust property is QTIP within the meaning of sec. 2056(b)(7), I.R.C. This Court's opinions in Estate of Robertson v. Commissioner, 98 T.C. 678 (1992), revd. 15 F.3d 779 (8th Cir. 1994); Estate of Clayton v.…
1Opinion of the Court
ESTATE OF WILLIS EDWARD CLACK, DECEASED, MARSHALL & ILSLEY TRUST COMPANY, CO-PERSONAL REPRESENTATIVE, AND RICHARD E. CLACK, CO-PERSONAL REPRESENTATIVE, Petitoner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Estate of Clack v. Commissioner
Docket No. 12557-91.
United States Tax Court
106 T.C. 131; 1996 U.S. Tax Ct. LEXIS 6; 106 T.C. No. 6;
February 29, 1996, Filed
Decedent's will gave his surviving spouse an income interest in certain marital trust property but provided that if decedent's coexecutors did not elect to treat the property as "qualified terminable interest property" (QTIP) within the…
Also in this document: Concurrence · Chabot; Concurrence · Swift; Concurrence · Gerber; Concurrence · Beghe; Dissent · Parker; Dissent · Halpern.
2Cases cited59 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- Immigration & Naturalization Service v. Cardoza-FonsecaSupreme Court of the United States · 1987
- Thomas Jefferson University v. ShalalaSupreme Court of the United States · 1994
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- National Muffler Dealers Assn., Inc. v. United StatesSupreme Court of the United States · 1979
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