Legal Opinion

Estate of Wall v. Commissioner

United States Tax Court

Decided October 12, 1993No. Docket No. 15311-91Published

The decedent created three irrevocable inter vivos trusts, as to each of which she retained the right to remove the sole trustee, a corporation qualified to conduct trust business, and substitute a different corporation qualified to conduct trust business. She also retained the right to contribute additional assets to the trusts. She retained no other power, right or interest in the trusts.

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The decedent created three irrevocable inter vivos trusts, as to each of which she retained the right to remove the sole trustee, a corporation qualified to conduct trust business, and substitute a different corporation qualified to conduct trust business. She also retained the right to contribute additional assets to the trusts. She retained no other power, right or interest in the trusts. The trustee's powers to distribute income and principal were essentially not limited by any ascertainable standard. Held, the assets of the trusts are not required to be included in the decedent's gross…

1Opinion of the Court

Estate of Helen S. Wall, Deceased, Kathryn H. Barth, Personal Representative, Petitioner v. Commissioner of Internal Revenue, Respondent

Estate of Wall v. Commissioner

Docket No. 15311-91

United States Tax Court

101 T.C. 300; 1993 U.S. Tax Ct. LEXIS 62; 101 T.C. No. 21;

October 12, 1993, Filed

Decision will be entered for petitioner.

The decedent created three irrevocable inter vivos trusts, as to each of which she retained the right to remove the sole trustee, a corporation qualified to conduct trust business, and substitute a different corporation qualified to conduct trust business. She also…

2Cases cited19 opinions

  1. Helvering v. CliffordSupreme Court of the United States · 1940
  2. United States v. ByrumSupreme Court of the United States · 1972
  3. United States v. O'MALLEYSupreme Court of the United States · 1966
  4. Galt v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1954
  5. Galt v. CommissionerUnited States Tax Court · 1953

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