Miller v. Commissioner
United States Tax Court
1. Held, contributions to an irrevocable trust, the funds of which must ultimately go to charities described in section 170(c), I.R.C. 1954, are "for the use of" such charities and are deductible under section 170. 2. Held, the income of an irrevocable trust, created for the purpose of receiving funds ultimately to benefit charities, over which the settlor exercised no administrative powers except in a fiduciary capacity, had no reversionary interest, had no power to alter…
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1. Held, contributions to an irrevocable trust, the funds of which must ultimately go to charities described in section 170(c), I.R.C. 1954, are "for the use of" such charities and are deductible under section 170. 2. Held, the income of an irrevocable trust, created for the purpose of receiving funds ultimately to benefit charities, over which the settlor exercised no administrative powers except in a fiduciary capacity, had no reversionary interest, had no power to alter or amend, and was prohibited from dealing with the trust individually, is not taxable to the settlor.
1Opinion of the Court
Emerson R. Miller and Mary McClure Miller v. Commissioner.
Miller v. Commissioner
Docket No. 83723.
United States Tax Court
T.C. Memo 1960-267; 1960 Tax Ct. Memo LEXIS 24; 19 T.C.M. (CCH) 1487; T.C.M. (RIA) 60267;
December 12, 1960
1. Held, contributions to an irrevocable trust, the funds of which must ultimately go to charities described in section 170(c), I.R.C. 1954, are "for the use of" such charities and are deductible under section 170.
2. Held, the income of an irrevocable trust, created for the purpose of receiving funds ultimately to benefit charities, over which the settlor exercised no…
2Cases cited7 opinions
- Danz v. CommissionerUnited States Tax Court · 1952
- The John Danz Charitable Trust v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1956
- United States v. PierceCourt of Appeals for the Eighth Circuit · 1943
- American Issue Publishing Co. v. EvattOhio Supreme Court · 1940
- Cherry v. CommissionerUnited States Tax Court · 1944
2 more not listed; retrieve them via the Exa API.