Coleman Trust v. Commissioner
United States Tax Court
The individual taxpayer in these proceedings was made the income beneficiary for life of a trust which her husband created in 1934. She was to receive the entire net income of the trust each year. In case the income from the trust in any year was less than $ 12,000, the trustees were directed to pay to the beneficiary upon her written request enough out of the principal of the trust estate to make up the full $ 12,000 per annum.
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The individual taxpayer in these proceedings was made the income beneficiary for life of a trust which her husband created in 1934. She was to receive the entire net income of the trust each year. In case the income from the trust in any year was less than $ 12,000, the trustees were directed to pay to the beneficiary upon her written request enough out of the principal of the trust estate to make up the full $ 12,000 per annum. In the three taxable years involved in these proceedings, the income of the trust was not sufficient to pay the beneficiary $ 12,000 per annum and upon her written…
1Opinion of the Court
Horace C. Coleman Trust, The Pennsylvania Company for Insurances on Lives and Granting Annuities, Eleanor B. Klemm and Philip F. Coleman, Trustees, Petitioner, v. Commissioner of Internal Revenue, Respondent. Helen W. Coleman, Petitioner, v. Commissioner of Internal Revenue, Respondent
Coleman Trust v. Commissioner
Docket Nos. 1585, 1586
United States Tax Court
3 T.C. 943; 1944 U.S. Tax Ct. LEXIS 108;
June 5, 1944, Promulgated
In Docket No. 1585 decision will be entered for petitioner. In Docket No. 1586 decision will be entered for respondent.
The individual taxpayer in these proceedings was made…
2Cases cited2 opinions
- Frankel v. CommissionerUnited States Tax Court · 1944
- Coleman Trust v. CommissionerUnited States Tax Court · 1944