Estate of Robinson v. Commissioner
United States Tax Court
D's late husband bequeathed his estate to a marital trust, for the benefit of D, and a residuary trust, for the benefit of his children and grandchildren. The marital trust was to be funded by one-half of the assets of the estate and the residuary trust was to be funded by the remaining assets of the estate. The will gave D a testamentary power of appointment over the assets of the marital trust.
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D's late husband bequeathed his estate to a marital trust, for the benefit of D, and a residuary trust, for the benefit of his children and grandchildren. The marital trust was to be funded by one-half of the assets of the estate and the residuary trust was to be funded by the remaining assets of the estate. The will gave D a testamentary power of appointment over the assets of the marital trust. If D failed to exercise her testamentary power of appointment, the assets of the marital trust were to pass to the beneficiaries of the residuary trust. a family dispute ensued, and neither of the…
1Opinion of the Court
Wells, Judge:
Respondent determined a deficiency in the Federal gift tax of Inez T. Robinson (decedent) in the amount of $717,252 for taxable year 1983. In addition, respondent determined a deficiency in decedent’s estate’s (petitioner’s) Federal estate tax in the amount of $276,411. Petitioner filed separate petitions with respect to the gift tax deficiency and the estate tax deficiency. The instant cases have been consolidated for purposes of trial, briefing, and opinion (hereinafter referred to as the instant case).
After concessions, the following issues remain to be decided: (1) Whether…
2Cases cited20 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Aquilino v. United StatesSupreme Court of the United States · 1960
- United States v. PelzerSupreme Court of the United States · 1941
- Commissioner v. DanielsonCourt of Appeals for the Third Circuit · 1967
- Danielson v. CommissionerUnited States Tax Court · 1965
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3Cited by2 opinions
- Estate of Robinson v. CommissionerUnited States Tax Court · 1993
- United States v. Bethann Scharrer Liquidating TrusteeDistrict Court, M.D. Florida · 1999