Fidelity Union Trust Co. v. Commissioner
United States Board of Tax Appeals
Petitioners' decedent transferred property in trust in 1923 to pay the income therefrom to him for life and upon his death to distribute part of the corpus to his two children and add the balance to other trusts previously created for the benefit of the children. In the event of the children predeceasing the grantor the property was to go to his executor or administrator for distribution.
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Petitioners' decedent transferred property in trust in 1923 to pay the income therefrom to him for life and upon his death to distribute part of the corpus to his two children and add the balance to other trusts previously created for the benefit of the children. In the event of the children predeceasing the grantor the property was to go to his executor or administrator for distribution. Both children survived the grantor, who died February 25, 1931. Held, that the children took vested interests under the trust deed and that upon the death of the grantor there was no transfer subject to…
1Opinion of the Court
FIDELITY UNION TRUST COMPANY AND MELVIN SPENCER, EXECUTORS OF THE ESTATE OF GEORGE FRINCK SPENCER, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Fidelity Union Trust Co. v. Commissioner
Docket No. 72236.
United States Board of Tax Appeals
31 B.T.A. 171; 1934 BTA LEXIS 1149;
September 14, 1934, Promulgated
Petitioners' decedent transferred property in trust in 1923 to pay the income therefrom to him for life and upon his death to distribute part of the corpus to his two children and add the balance to other trusts previously created for the benefit of the children. In the event of…
2Cases cited1 opinion
- Fidelity Union Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1934