Estate of Engelman v. Comm'r
United States Tax Court
In 1990, H and D, husband and wife, established a living trust. The terms of the trust provided for an allocation of trust assets between two separate trusts, Trust A and Trust B, upon the death of the first spouse. Initially, all assets were to be placed in Trust A except to the extent disclaimed by the surviving spouse.
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In 1990, H and D, husband and wife, established a living trust. The terms of the trust provided for an allocation of trust assets between two separate trusts, Trust A and Trust B, upon the death of the first spouse. Initially, all assets were to be placed in Trust A except to the extent disclaimed by the surviving spouse. Disclaimed assets were to be placed in Trust B. The surviving spouse was also granted a power of appointment effective at death over Trust A. H died on Dec. 30, 1997. On Feb. 5, 1998, D executed a document entitled "Power of Appointment" directing disposition of the Trust A…
1Opinion of the Court
ESTATE OF LEONA ENGELMAN, DECEASED, PEGGY D. MATTSON, EXECUTOR, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Estate of Engelman v. Comm'r
No. 4668-02
United States Tax Court
121 T.C. 54; 2003 U.S. Tax Ct. LEXIS 23; 121 T.C. No. 4;
July 24, 2003, Filed
Estate was not entitled to charitable deductions for amounts distributed to beneficiaries named in Trust B of Engelman Living Trust.
In 1990, H and D, husband and wife, established a living
trust. The terms of the trust provided for an allocation of
trust assets between two separate trusts, Trust A and Trust B,
upon the death of the first…
2Cases cited15 opinions
- Jewett v. CommissionerSupreme Court of the United States · 1982
- United States v. IrvineSupreme Court of the United States · 1994
- McDonald v. CommissionerUnited States Tax Court · 1987
- Continental Illinois National Bank and Trust Company of Chicago v. The United StatesUnited States Court of Claims · 1968
- Nellis v. RickardCalifornia Supreme Court · 1901
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