Legal Opinion

Froman Trust v. Commissioner

United States Tax Court

Decided June 20, 1972No. Docket No. 3704-70Published

Decedent established a testamentary trust, which was to distribute income to charitable and noncharitable beneficiaries and the remainder to charity. The trustees were given certain discretionary powers with respect to the acquisition and disposition of trust property and with respect to the allocation of receipts between income and principal.

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Decedent established a testamentary trust, which was to distribute income to charitable and noncharitable beneficiaries and the remainder to charity. The trustees were given certain discretionary powers with respect to the acquisition and disposition of trust property and with respect to the allocation of receipts between income and principal. Held, under the terms of the will and the applicable Illinois law, the trustees' discretionary powers were so restricted that the value of the charitable remainder was ascertainable.

1Opinion of the Court

Kate Froman Trust, Adolph Sievers, and Security Bank and Trust Company of Mt. Carmel, Co-trustees, Petitioners v. Commissioner of Internal Revenue, Respondent

Froman Trust v. Commissioner

Docket No. 3704-70

United States Tax Court

58 T.C. 512; 1972 U.S. Tax Ct. LEXIS 104;

June 20, 1972, Filed

Decision will be entered under Rule 50.

Decedent established a testamentary trust, which was to distribute income to charitable and noncharitable beneficiaries and the remainder to charity. The trustees were given certain discretionary powers with respect to the acquisition and disposition of trust property and…

2Cases cited20 opinions

  1. Ithaca Trust Co. v. United StatesSupreme Court of the United States · 1929
  2. Henslee v. Union Planters National Bank & Trust Co.Supreme Court of the United States · 1949
  3. Commissioner v. Estate of SternbergerSupreme Court of the United States · 1955
  4. Estate of Lillie MacMunn Stewart, Deceased, W. Alan Henderson v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1971
  5. The Miami Beach First National Bank, as Under the Will of Lenore P. Hartz, Deceased v. United StatesCourt of Appeals for the First Circuit · 1971

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