Legal Opinion

Estate of Crafts v. Commissioner

United States Tax Court

Decided September 25, 1980No. Docket No. 4443-79Published

Decedent possessed an inter vivos power of appointment over property held in trust; said property was includable in her gross estate under sec. 2041, I.R.C. 1954. The trust, which had been established under the will of the decedent's predeceased husband, provided for income interests in favor of various individuals as well as a 40-percent income interest for the benefit of the Webb Institute (Webb), a charitable organization.

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Decedent possessed an inter vivos power of appointment over property held in trust; said property was includable in her gross estate under sec. 2041, I.R.C. 1954. The trust, which had been established under the will of the decedent's predeceased husband, provided for income interests in favor of various individuals as well as a 40-percent income interest for the benefit of the Webb Institute (Webb), a charitable organization. The remainder interest was divided between Webb and another charity in the respective proportions of 75 and 25 percent. The estate's representative requested a ruling…

1Opinion of the Court

Estate of Nancy F. Crafts, Deceased, William A. Dicus, Personal Representative, Petitioner v. Commissioner of Internal Revenue, Respondent

Estate of Crafts v. Commissioner

Docket No. 4443-79

United States Tax Court

74 T.C. 1439; 1980 U.S. Tax Ct. LEXIS 50; 74 T.C. No. 105;

September 25, 1980, Filed

Decision will be entered under Rule 155.

Decedent possessed an inter vivos power of appointment over property held in trust; said property was includable in her gross estate under sec. 2041, I.R.C. 1954. The trust, which had been established under the will of the decedent's predeceased husband, provided…

2Cases cited15 opinions

  1. Lyeth v. HoeySupreme Court of the United States · 1938
  2. National Muffler Dealers Assn., Inc. v. United StatesSupreme Court of the United States · 1979
  3. Helvering v. BlissSupreme Court of the United States · 1934
  4. Helvering v. ReynoldsSupreme Court of the United States · 1941
  5. Groman v. CommissionerSupreme Court of the United States · 1937

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