Moore Trust v. Commissioner

Trustee of petitioner was the defendant in a State court litigation brought by the beneficial remaindermen of petitioner to have their interests accelerated following the renunciation by the life income beneficiary of part of her interest. The complaint in the State court action prayed that the trustee be ordered to set up separate trusts of equal amount for the respective benefit of each remainderman. The court decided adversely to the remaindermen's claim, which decision was affirmed on appeal. However, the court, in accordance with State law, charged the legal expenses of all the parties…