Legal Opinion

Estate of Reid v. Commissioner

United States Tax Court

Decided February 15, 1979No. Docket No. 9215-76Published

Decedent established an inter vivos irrevocable trust in 1955 and transferred property to the Mercantile National Bank of Dallas as trustee to be held by the trustee for the benefit of specified beneficiaries. Under the trust, the trustee had the discretionary right to distribute trust property and income therefrom to the designated beneficiaries during the life of decedent.

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Decedent established an inter vivos irrevocable trust in 1955 and transferred property to the Mercantile National Bank of Dallas as trustee to be held by the trustee for the benefit of specified beneficiaries. Under the trust, the trustee had the discretionary right to distribute trust property and income therefrom to the designated beneficiaries during the life of decedent. In addition, the trust provided that, in the event the trustee resigned, the decedent, if living, had the right to appoint a successor trustee. Nothing in the trust provisions prohibited decedent from appointing herself…

1Opinion of the Court

Estate of Ruth T. Reid, Deceased, Walter D. Reid, Independent Executor, Petitioner v. Commissioner of Internal Revenue, Respondent

Estate of Reid v. Commissioner

Docket No. 9215-76

United States Tax Court

71 T.C. 816; 1979 U.S. Tax Ct. LEXIS 172;

February 15, 1979, Filed

Decision will be entered under Rule 155.

Decedent established an inter vivos irrevocable trust in 1955 and transferred property to the Mercantile National Bank of Dallas as trustee to be held by the trustee for the benefit of specified beneficiaries. Under the trust, the trustee had the discretionary right to distribute trust…

2Cases cited16 opinions

  1. City Bank Farmers Trust Co. v. McGowanSupreme Court of the United States · 1945
  2. Hurd v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1947
  3. Alonzo Wimberly Jenkins, Jr., as Executors Under the Will of Martha O. Jenkins, Deceased v. United StatesCourt of Appeals for the Fifth Circuit · 1970
  4. Hurd v. CommissionerUnited States Tax Court · 1946
  5. Clarence Blagen Fish, Administrator With the Will Annexed of the Estate of Minnie C. Blagen, Deceased v. United StatesCourt of Appeals for the Ninth Circuit · 1970

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