Estate of Carli v. Comm'r
United States Tax Court
In 1972, decedent, a California resident, created a revocable trust in which he retained a life estate. Decedent transferred his residence to the trust. On the same day that he created the trust, the decedent executed a pour-over will. In 1974, the decedent and his then fiancee, J, entered into an antenuptial agreement, under which decedent agreed to amend the trust and will to provide J with a life estate in the residence upon his death.
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In 1972, decedent, a California resident, created a revocable trust in which he retained a life estate. Decedent transferred his residence to the trust. On the same day that he created the trust, the decedent executed a pour-over will. In 1974, the decedent and his then fiancee, J, entered into an antenuptial agreement, under which decedent agreed to amend the trust and will to provide J with a life estate in the residence upon his death. J's right to a life estate was conditioned on the parties' being married at decedent's death, and was defeasible in the event that she subsequently…
1Opinion of the Court
Estate of Joseph M. Carli, Deceased, Robert J. Carli, Executor, Petitioner v. Commissioner of Internal Revenue, Respondent
Estate of Carli v. Comm'r
Docket No. 21753-81
United States Tax Court
84 T.C. 649; 1985 U.S. Tax Ct. LEXIS 95; 84 T.C. No. 43;
April 9, 1985. April 9, 1985, Filed
Decision will be entered for the respondent.
In 1972, decedent, a California resident, created a revocable trust in which he retained a life estate. Decedent transferred his residence to the trust. On the same day that he created the trust, the decedent executed a pour-over will. In 1974, the decedent and his then…
Also in this document: Concurrence; Dissent.
2Cases cited36 opinions
- United States v. DavisSupreme Court of the United States · 1962
- Achiro v. CommissionerUnited States Tax Court · 1981
- Merrill v. FahsSupreme Court of the United States · 1945
- Barham v. BarhamCalifornia Supreme Court · 1949
- See v. SeeCalifornia Supreme Court · 1966
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