Morris Trusts v. Commissioner
United States Tax Court
1. In 1953, grantors executed 10 irrevocable declarations of trust, each of which directed the trustee, subject to certain discretionary distributions, to accumulate the income for the life of each of two primary beneficiaries and, upon the death of both of them, to distribute the principal and accumulated income to trusts to be created for their surviving issue.
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1. In 1953, grantors executed 10 irrevocable declarations of trust, each of which directed the trustee, subject to certain discretionary distributions, to accumulate the income for the life of each of two primary beneficiaries and, upon the death of both of them, to distribute the principal and accumulated income to trusts to be created for their surviving issue. The 10 instruments were similar in form except for differing periods for income accumulation and distribution, and differing termination dates. The trust property under each declaration was combined or pooled for administrative…
1Opinion of the Court
FeatheRSton, Judge:
Respondent determined deficiencies against petitioner in the following amounts:
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These deficiencies arise out of respondent’s determination that certain trusts created by 10 trust instruments executed by E. S. Morris and Etty Morris on September 11,1953, constituted two trusts for Federal income tax purposes, rather than 20 trusts as reported. Each notice of deficiency contained the following statement explaining the determination : “It is determined that you constitute a single trust for federal income tax purposes under the provisions of sections 61, 642, 643,…
2Cases cited34 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Helvering v. CliffordSupreme Court of the United States · 1940
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Commissioner v. TowerSupreme Court of the United States · 1946
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
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3Cited by17 opinions
- Skripak v. CommissionerUnited States Tax Court · 1985
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- University Hill Foundation v. CommissionerUnited States Tax Court · 1969
- Bank of New York Mellon Corp. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 2015
- Buehner v. CommissionerUnited States Tax Court · 1976
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