Rand v. Commissioner
United States Tax Court
The petitioner was both the income and remainder beneficiary, as well as one of the trustees, of a trust created in Missouri. Under an agreement between him and the other trustees, the trustees' fees were based in part upon a percentage of the value of a part of the corpus of the trust as of the time of distribution.
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The petitioner was both the income and remainder beneficiary, as well as one of the trustees, of a trust created in Missouri. Under an agreement between him and the other trustees, the trustees' fees were based in part upon a percentage of the value of a part of the corpus of the trust as of the time of distribution. Held, that under Missouri law and upon the particular facts presented, such trustees' fees were properly paid out of income of the trust, and served to reduce the distributable income of the trust which was taxable to the petitioner in the year of termination of the trust.
1Opinion of the Court
Norfleet H. Rand and Eloise S. Rand, Petitioners, v. Commissioner of Internal Revenue, Respondent
Rand v. Commissioner
Docket No. 66462
United States Tax Court
33 T.C. 548; 1959 U.S. Tax Ct. LEXIS 10;
December 21, 1959, Filed
Decision will be entered under Rule 50.
The petitioner was both the income and remainder beneficiary, as well as one of the trustees, of a trust created in Missouri. Under an agreement between him and the other trustees, the trustees' fees were based in part upon a percentage of the value of a part of the corpus of the trust as of the time of distribution. Held, that under…
2Cases cited13 opinions
- Freuler v. HelveringSupreme Court of the United States · 1934
- Trust Under the Will of Bingham v. CommissionerSupreme Court of the United States · 1945
- Fiske v. BuderCourt of Appeals for the Eighth Circuit · 1942
- In Re BuderSupreme Court of Missouri · 1949
- Carlisle v. CommissionerCourt of Appeals for the Sixth Circuit · 1948
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