Polster v. Commissioner
United States Tax Court
Under decedent's will, his residuary estate was to be held in trust to provide annuities for two adult children. After the end of such life interests, the trust was to continue for the purpose of providing funds for church properties. All disbursements of trust corpus for such purposes were restricted to not more than 25 per cent of the cost of each church property.
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Under decedent's will, his residuary estate was to be held in trust to provide annuities for two adult children. After the end of such life interests, the trust was to continue for the purpose of providing funds for church properties. All disbursements of trust corpus for such purposes were restricted to not more than 25 per cent of the cost of each church property. Held, under all of the facts and circumstances, the possibility that charity will not take the entire bequest is not so remote as to be either negligible or highly improbable and, therefore, the estate is not entitled to a…
1Opinion of the Court
Estate of John C. Polster, Deceased, Milton A. Polster, and J. Paul Rocklin, Executors, Petitioners, v. Commissioner of Internal Revenue, Respondent
Polster v. Commissioner
Docket No. 66617
United States Tax Court
31 T.C. 874; 1959 U.S. Tax Ct. LEXIS 252;
January 28, 1959, Filed
Decision will be entered for the respondent.
Under decedent's will, his residuary estate was to be held in trust to provide annuities for two adult children. After the end of such life interests, the trust was to continue for the purpose of providing funds for church properties. All disbursements of trust corpus for such…
2Cases cited23 opinions
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- Helvering v. HallockSupreme Court of the United States · 1940
- Henslee v. Union Planters National Bank & Trust Co.Supreme Court of the United States · 1949
- Merchants Nat. Bank of Boston v. CommissionerSupreme Court of the United States · 1943
- Klein v. United StatesSupreme Court of the United States · 1931
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