Solomon v. Commissioner
United States Tax Court
Undistributable capital gains earned by an irrevocable trust in 1950 are not taxable under facts of case to the grantor-life beneficiary of the trust who retained (1) limited power to invade the corpus, (2) a right to alter the shares of a designated class of remaindermen, (3) a contingent right to dispose of the trust corpus by will if she survived her mother, her issue, and their children, and (4) the right to become co-trustee with broad managerial powers to act as a…
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Undistributable capital gains earned by an irrevocable trust in 1950 are not taxable under facts of case to the grantor-life beneficiary of the trust who retained (1) limited power to invade the corpus, (2) a right to alter the shares of a designated class of remaindermen, (3) a contingent right to dispose of the trust corpus by will if she survived her mother, her issue, and their children, and (4) the right to become co-trustee with broad managerial powers to act as a fiduciary.
1Opinion of the Court
Estate of Hiram Solomon, Deceased, Carolyn Manson (Formerly Carolyn Solomon), Administratrix, and Carolyn Manson (Formerly Carolyn Solomon), Petitioners, v. Commissioner of Internal Revenue, Respondent
Solomon v. Commissioner
Docket No. 54472
United States Tax Court
27 T.C. 426; 1956 U.S. Tax Ct. LEXIS 24;
November 30, 1956, Filed
Decision will be entered for petitioners.
Undistributable capital gains earned by an irrevocable trust in 1950 are not taxable under facts of case to the grantor-life beneficiary of the trust who retained (1) limited power to invade the corpus, (2) a right to alter the…
2Cases cited10 opinions
- Helvering v. CliffordSupreme Court of the United States · 1940
- Hutchison v. RossNew York Court of Appeals · 1933
- Commissioner of Internal Revenue v. BuckCourt of Appeals for the Second Circuit · 1941
- Commissioner of Internal Revenue v. BatemanCourt of Appeals for the First Circuit · 1942
- In re the Bank of RichmondvilleAppellate Division of the Supreme Court of the State of New York · 1940
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