Estate of Howard v. Commissioner
United States Tax Court
A surviving spouse received an income interest in a trust. Under the terms of the trust, the income accumulating between the last distribution date and the surviving spouse's death passed to the remainder beneficiaries of the trust. Held, the trust is not a qualified terminable interest property trust. Sec. 2056(b)(7), I.R.C. 1954.
1Opinion of the Court
Estate of Rose D. Howard, Deceased, Roger W. A. Howard, Volney E. Howard III, Alanson L. Howard, Robert L. Briner, Trustees, Petitioners v. Commissioner of Internal Revenue, Respondent
Estate of Howard v. Commissioner
Docket No. 9208-87
United States Tax Court
91 T.C. 329; 1988 U.S. Tax Ct. LEXIS 111; 91 T.C. No. 26;
August 23, 1988. August 23, 1988, Filed
Decision will be entered under Rule 155.
A surviving spouse received an income interest in a trust. Under the terms of the trust, the income accumulating between the last distribution date and the surviving spouse's death passed to the remainder…
2Cases cited12 opinions
- United States v. WellsSupreme Court of the United States · 1931
- Sorenson v. Secretary of the TreasurySupreme Court of the United States · 1986
- Jackson v. United StatesSupreme Court of the United States · 1964
- Elizabeth Joan Allen and Alice Edna Stuhmer, Individually and as Executrices of the Estate of Chester A. Allen, Deceased v. United StatesCourt of Appeals for the Second Circuit · 1966
- Scott v. CommissionerUnited States Tax Court · 1985
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