Estate of Hazelton v. Commissioner
United States Tax Court
Decedent, the principal beneficiary in a trust created by his father in 1935, was not subject to a gift tax in 1951 when the trustees of the 1935 trust transferred a portion of the trust assets to a new trust in which the decedent was again the principal beneficiary, but with the difference that in the new trust the decedent's spouse was entitled, at the absolute discretion of the trustees, to a distribution of principal and income for her welfare, while under the old trust…
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Decedent, the principal beneficiary in a trust created by his father in 1935, was not subject to a gift tax in 1951 when the trustees of the 1935 trust transferred a portion of the trust assets to a new trust in which the decedent was again the principal beneficiary, but with the difference that in the new trust the decedent's spouse was entitled, at the absolute discretion of the trustees, to a distribution of principal and income for her welfare, while under the old trust such distribution to the spouse was limited to one-third of the trust income.
1Opinion of the Court
Estate of Franklin Lewis Hazelton, Deceased, Mary Hazelton, Administratrix With the Will Annexed, Petitioner, v. Commissioner of Internal Revenue, Respondent
Estate of Hazelton v. Commissioner
Docket No. 58284
United States Tax Court
29 T.C. 637; 1957 U.S. Tax Ct. LEXIS 4;
December 31, 1957, Filed
Decision will be entered under Rule 50.
Decedent, the principal beneficiary in a trust created by his father in 1935, was not subject to a gift tax in 1951 when the trustees of the 1935 trust transferred a portion of the trust assets to a new trust in which the decedent was again the principal beneficiary,…
2Cases cited2 opinions
- Lahti v. CommissionerUnited States Tax Court · 1946
- Estate of Hazelton v. CommissionerUnited States Tax Court · 1957