Davis v. Commissioner
United States Tax Court
1. The petitioner established an inter vivos trust under the terms of which income and principal was to be used for the college education of his grandnieces and grandnephews. At the time of the gift it was likely that the corpus of the trust would be exhausted; however, the petitioner provided that the remainder, if any, would go to a charitable foundation. Held: Charitable deduction was properly disallowed.
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1. The petitioner established an inter vivos trust under the terms of which income and principal was to be used for the college education of his grandnieces and grandnephews. At the time of the gift it was likely that the corpus of the trust would be exhausted; however, the petitioner provided that the remainder, if any, would go to a charitable foundation. Held: Charitable deduction was properly disallowed. The trust was established for a private rather than the public charitable purpose required by sec. 2522(a)(2), I.R.C. 1954. 2. The petitioners made gifts in trust for the benefit of their…
1Opinion of the Court
Samuel S. Davis and Jeanette A. Davis, 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Davis v. Commissioner
Docket Nos. 2383-69, 2384-69
United States Tax Court
55 T.C. 416; 1970 U.S. Tax Ct. LEXIS 16;
December 9, 1970, Filed
Decisions will be entered for the respondent.
1. The petitioner established an inter vivos trust under the terms of which income and principal was to be used for the college education of his grandnieces and grandnephews. At the time of the gift it was likely that the corpus of the trust would be exhausted; however, the petitioner provided that the remainder, if…
2Cases cited21 opinions
- Messing v. CommissionerUnited States Tax Court · 1967
- Commissioner v. Estate of SternbergerSupreme Court of the United States · 1955
- Arnold Van Den Wymelenberg, as of the Estate of Eleanor Van Den Wymelenberg, and Arnold Van Den Wymelenberg v. United StatesCourt of Appeals for the Seventh Circuit · 1968
- Will Flitcroft and Agnes D. Flitcroft v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1964
- M.T. Straight's Trust, Francis L. McCrea Trustee v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1957
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