Estate of Sorenson v. Commissioner
United States Tax Court
Decedent had a general power of appointment over assets left in trust by her husband's will which, absent her exercise, went into a trust with a remainder interest passing to a charity. Her husband died on May 30, 1969. Decedent, who died on Feb. 22, 1974, had not exercised this power in her will executed on Jan. 24, 1969. She was not incompetent at any time prior to her death.
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Decedent had a general power of appointment over assets left in trust by her husband's will which, absent her exercise, went into a trust with a remainder interest passing to a charity. Her husband died on May 30, 1969. Decedent, who died on Feb. 22, 1974, had not exercised this power in her will executed on Jan. 24, 1969. She was not incompetent at any time prior to her death. The trust into which the assets went upon decedent's failure to exercise the power of appointment created by the will of decedent's husband was not a charitable remainder annuity trust or a unitrust under sec. 664,…
1Opinion of the Court
Estate of Vera S. Sorenson, Lola L. Bonner, Independent Executrix, Petitioner v. Commissioner of Internal Revenue, Respondent
Estate of Sorenson v. Commissioner
Docket No. 3970-77
United States Tax Court
72 T.C. 1180; 1979 U.S. Tax Ct. LEXIS 52;
September 25, 1979, Filed
Decision will be entered for the respondent.
Decedent had a general power of appointment over assets left in trust by her husband's will which, absent her exercise, went into a trust with a remainder interest passing to a charity. Her husband died on May 30, 1969. Decedent, who died on Feb. 22, 1974, had not exercised this power in…
2Cases cited20 opinions
- Morgan v. CommissionerSupreme Court of the United States · 1940
- Lyeth v. HoeySupreme Court of the United States · 1938
- Helvering v. StuartSupreme Court of the United States · 1942
- United States v. PelzerSupreme Court of the United States · 1941
- Chanler v. KelseySupreme Court of the United States · 1907
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