Estate of Fabric v. Commissioner
United States Tax Court
Five days prior to her open-heart surgery, decedent created a foreign trust and entered into an annuity agreement with the trustee of the foreign trust. The trust was initially funded with $ 750. It was irrevocable, and decedent did not retain any control over it. The trust's beneficiaries were decedent's four sons and their lineal descendants. Pursuant to the annuity agreement, the foreign trustee agreed to pay decedent during her lifetime a fixed weekly amount.
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Five days prior to her open-heart surgery, decedent created a foreign trust and entered into an annuity agreement with the trustee of the foreign trust. The trust was initially funded with $ 750. It was irrevocable, and decedent did not retain any control over it. The trust's beneficiaries were decedent's four sons and their lineal descendants. Pursuant to the annuity agreement, the foreign trustee agreed to pay decedent during her lifetime a fixed weekly amount. The annuity amount was determined by use of the tables set forth in sec. 20.2031-10, Estate Tax Regs., and it was not dependent on…
1Opinion of the Court
Estate of Mollie P. Fabric, Elliot Fabric, Personal Representative, Petitioner v. Commissioner of Internal Revenue, Respondent
Estate of Fabric v. Commissioner
Docket No. 17536-81
United States Tax Court
83 T.C. 932; 1984 U.S. Tax Ct. LEXIS 4; 83 T.C. No. 50;
December 11, 1984. December 11, 1984, Filed
Decision will be entered under Rule 155.
Five days prior to her open-heart surgery, decedent created a foreign trust and entered into an annuity agreement with the trustee of the foreign trust. The trust was initially funded with $ 750. It was irrevocable, and decedent did not retain any control over…
2Cases cited5 opinions
- La Fargue v. CommissionerUnited States Tax Court · 1979
- Esther Lafargue v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1982
- Sidney B. Stern and Vera L. Stern v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1984
- Stern v. CommissionerUnited States Tax Court · 1981
- Estate of Fabric v. CommissionerUnited States Tax Court · 1984