Estate of Pollock v. Commissioner
United States Tax Court
Held, decedent-transferee's discretionary life interest in a trust created by prior decedent did not constitute a fixed right to all or even a determinable portion of the distributable income for the remainder of her life, and was therefore not susceptible of valuation so as to qualify for an estate tax credit under sec. 2013(a), I.R.C. 1954.
1Opinion of the Court
Estate of Shirley Pollock, Deceased, Neal J. Pollock, Personal Representative, Petitioner v. Commissioner of Internal Revenue, Respondent
Estate of Pollock v. Commissioner
Docket No. 2430-80
United States Tax Court
77 T.C. 1296; 1981 U.S. Tax Ct. LEXIS 8;
December 21, 1981, Filed
Decision will be entered under Rule 155.
Held, decedent-transferee's discretionary life interest in a trust created by prior decedent did not constitute a fixed right to all or even a determinable portion of the distributable income for the remainder of her life, and was therefore not susceptible of valuation so as to…
2Cases cited15 opinions
- Merchants Nat. Bank of Boston v. CommissionerSupreme Court of the United States · 1943
- A. A. Lewis & Co. v. CommissionerSupreme Court of the United States · 1937
- Knauer v. BarnettSupreme Court of Florida · 1978
- Samuel H. Salisbury, as Under the Will of Ora S. Hitchcock v. United StatesCourt of Appeals for the Second Circuit · 1967
- The Florida Bank at Lakeland and J. B. O'neill, Co-Executors of Estate of Hugh H. Nelson, Deceased, and Cross v. United StatesCourt of Appeals for the Fifth Circuit · 1971
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