Estate of O'Connor v. Commissioner
United States Tax Court
Decedent left one-half of his net estate in trust (marital trust) for his wife, who was given the income therefrom, a general testamentary power of appointment, and a power to withdraw any or all of corpus at any time by filing a written election with the trustees.
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Decedent left one-half of his net estate in trust (marital trust) for his wife, who was given the income therefrom, a general testamentary power of appointment, and a power to withdraw any or all of corpus at any time by filing a written election with the trustees. Shortly after decedent's death, the wife filed a written election with the executors-trustees to withdraw all of the corpus of said trust and, that same day, executed an assignment of all of her rights therein to a charitable foundation. The foundation received cash and securities which constituted principal and income of the…
1Opinion of the Court
OPINION
Tannenwald, Judge:
Respondent determined the following deficiencies in the petitioners’ Federal income taxes:
TYE Oct. 31-Deficiency
Estate of A. Lindsay O’Connor. .1969 $275,443.00
1970 255,603.90
1971 174.335.76
TYE Dec. 31-Deficiency
Marital trust under will of of A. Lindsay O’Connor.1969 $276,752.00
1970 294,027.90
1971 157.938.76
Olive Price.1970 70,460.50
1971 62,283.11
Robert L. and Lucille S. Bishop.1970 74,122.65
1971 41,496.34
Donald F. and Edna G. Bishop.1970 76,580.90
1971 41,565.09
The issues before us are:(1) Whether the decedent’s estate properly claimed distributions deductions in…
2Cases cited33 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Blair v. CommissionerSupreme Court of the United States · 1937
- Furman v. CommissionerUnited States Tax Court · 1966
- Irvine K. Furman and Lorena K. Furman v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
- Crosby Valve & Gage Company (Formerly Crosby Steam Gage & Valve Company) v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1967
28 more not listed; retrieve them via the Exa API.
3Cited by26 opinions
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- Estate of Johnson v. CommissionerUnited States Tax Court · 1987
- American Nurseryman Publishing Co. v. CommissionerUnited States Tax Court · 1980
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