Estate of Wilson
United States Tax Court
During life, D and W placed their community property into a revocable inter vivos trust. Under the terms of the trust, after D died, W was the sole trustee, and she was entitled to all income during her life. The trust also gave the trustee complete discretionary power to appoint corpus. Should W cease to act as trustee, she alone had the power to appoint and dismiss any successor trustees.
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During life, D and W placed their community property into a revocable inter vivos trust. Under the terms of the trust, after D died, W was the sole trustee, and she was entitled to all income during her life. The trust also gave the trustee complete discretionary power to appoint corpus. Should W cease to act as trustee, she alone had the power to appoint and dismiss any successor trustees. Upon the death of W, the trust was to distribute any remaining corpus to D's and W's children. Held: The trust satisfies the terms of sec. 2056(b)(5), I.R.C., and D's estate is entitled to a deduction for…
1Opinion of the Court
ESTATE OF IRVIN I. WILSON, JR., DECEASED, CATHERINE L. WILSON, PERSONAL REPRESENTATIVE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Estate of Wilson
Docket No. 3524-90
United States Tax Court
T.C. Memo 1992-479; 1992 Tax Ct. Memo LEXIS 502; 64 T.C.M. (CCH) 576;
August 24, 1992, Filed
Decision will be entered under Rule 155.
During life, D and W placed their community property into a revocable inter vivos trust. Under the terms of the trust, after D died, W was the sole trustee, and she was entitled to all income during her life. The trust also gave the trustee complete discretionary…
2Cases cited13 opinions
- Jackson v. United StatesSupreme Court of the United States · 1964
- Estate of Nicholson v. CommissionerUnited States Tax Court · 1990
- Estate of Doherty v. Comm'rUnited States Tax Court · 1990
- Estate of Jerome Mittleman, Deceased, Henrietta Mittleman, Irving B. Yochelson and Solomon Grossberg, Executors v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1975
- State v. CoerverArizona Supreme Court · 1966
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