Varian v. Commissioner
United States Tax Court
Decedent and his wife created three trusts, naming themselves as trustees, one for the benefit of each of three minor children of decedent. The trustees were given the discretion to pay or apply for the benefit of each child such sums as were necessary for the child's support, maintenance, and education.
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Decedent and his wife created three trusts, naming themselves as trustees, one for the benefit of each of three minor children of decedent. The trustees were given the discretion to pay or apply for the benefit of each child such sums as were necessary for the child's support, maintenance, and education. In addition, the trustees were given discretion to pay principal and income, in whole or in part, to the child at any time prior to the child's attaining the age of 21 years. The trustees were directed to distribute the unexpended principal and income to the child when he attained 21 or to…
1Opinion of the Court
Tannenwald, Judge:
The Commissioner determined a deficiency in estate tax in the amomit of $1,476,958.71. The petition alleges that the tax was overpaid in the amount of $81,025.58.
Prior to trial of the case, the parties executed an agreement of partial settlement, under which they made various settlements, concessions, and agreements respecting several of the issues raised .by the pleadings — with the result that the amount of tax hi controversy has been substantially reduced. This agreement will be given effect in the recomputation of tax to be made under Eule 50.
The issues remaining for…
2Cases cited23 opinions
- Ithaca Trust Co. v. United StatesSupreme Court of the United States · 1929
- Merchants Nat. Bank of Boston v. CommissionerSupreme Court of the United States · 1943
- Commissioner v. Estate of HolmesSupreme Court of the United States · 1946
- Siberell v. SiberellCalifornia Supreme Court · 1932
- United States v. O'MALLEYSupreme Court of the United States · 1966
18 more not listed; retrieve them via the Exa API.
3Cited by26 opinions
- Pardee v. CommissionerUnited States Tax Court · 1967
- Estate of Russell Harrison Varian, Etc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1968
- Estate of Stewart v. CommissionerUnited States Tax Court · 1969
- Stuit v. CommissionerUnited States Tax Court · 1970
- Dorothy Stuit, Transferee and Estate of Jennie Vanderpoel, Deceased, Dorothy Stuit v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1971
21 more not listed; retrieve them via the Exa API.