Legal Opinion

Thorrez v. Commissioner

United States Tax Court

Decided December 31, 1958No. Docket No. 57312PublishedCited by 28 opinions

1. Petitioner established four identical trusts for the benefit of minor grandchildren. The trustee of each trust was a parent of the beneficiaries. As each beneficiary reaches 21 years, his share of corpus is to be distributed to him.

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1. Petitioner established four identical trusts for the benefit of minor grandchildren. The trustee of each trust was a parent of the beneficiaries. As each beneficiary reaches 21 years, his share of corpus is to be distributed to him. During the minority of the beneficiaries, trust income is to be accumulated and invested as part of the corpus, but if a beneficiary should need money for support or education, the trustee may make payments from the trust estate, in such sums as he deems advisable, to a beneficiary or his legal guardian. Held, the gifts to each trust were of future interests…

1Opinion of the Court

OPINION.

Harron, Judge:

Isstie 1.

The trustee of each trust is directed during the minority of each beneficiary to accumulate the income and to reinvest such accumulated income as part of the corpus. When a beneficiary becomes 21 years of age, the trustee is directed to pay him his share of the corpus, including the accumulated income or the assets in which such income had been invested. During the minority of a beneficiary, the trustee may pay to a beneficiary, or his legal guardian, out of the trust estate such sums of money as the trustee deems advisable, “if” such beneficiary “should, need…

2Cases cited64 opinions

  1. Commissioner v. TowerSupreme Court of the United States · 1946
  2. Lusthaus v. CommissionerSupreme Court of the United States · 1946
  3. J. E. Riley Investment Co. v. CommissionerSupreme Court of the United States · 1940
  4. Smith v. ShaughnessySupreme Court of the United States · 1943
  5. Pacific National Co. v. WelchSupreme Court of the United States · 1938

59 more not listed; retrieve them via the Exa API.

3Cited by28 opinions

  1. Taylor v. CommissionerUnited States Tax Court · 1977
  2. Dougherty v. CommissionerUnited States Tax Court · 1973
  3. American Air Filter Co. v. CommissionerUnited States Tax Court · 1983
  4. Estate of Gunland v. CommissionerUnited States Tax Court · 1987
  5. Wilbur v. CommissionerUnited States Tax Court · 1964

23 more not listed; retrieve them via the Exa API.

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