Estate of James v. Commissioner
United States Tax Court
A decedent's will left his residuary estate in trust with the income payable to certain beneficiaries for life. It also provided that the principal might be invaded on behalf of the beneficiaries, during their lives, "either for comfortable maintenance and support, for educational requirements, illness, operations, or for any reason whatsoever which shall to my Trustees, in their sole discretion, seem sufficient."
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A decedent's will left his residuary estate in trust with the income payable to certain beneficiaries for life. It also provided that the principal might be invaded on behalf of the beneficiaries, during their lives, "either for comfortable maintenance and support, for educational requirements, illness, operations, or for any reason whatsoever which shall to my Trustees, in their sole discretion, seem sufficient." The remainder interest in the trust went in fee to a charity which qualifies under section 2055 of the 1954 Code for the charitable deduction. Held: The trustees were not limited in…
1Opinion of the Court
Hoyt, Judge:
The respondent determined a deficiency of $50,371.95 in the estate tax for the estate of Charles IT. James, deceased. A remainder interest in the principal of the testamentary trust created by his will was bequeathed to charity. The only adjustment which is contested is the disallowance of a charitable deduction of $138,808.41 for this bequest. The issue for decision is whether under the provision of the will an ascertainable standard is provided which limits the invasion of trust corpus for the benefit of the income beneficiaries.
FINDINGS OF FACT
Charles H. James, the decedent,…
2Cases cited9 opinions
- Ithaca Trust Co. v. United StatesSupreme Court of the United States · 1929
- Henslee v. Union Planters National Bank & Trust Co.Supreme Court of the United States · 1949
- Merchants Nat. Bank of Boston v. CommissionerSupreme Court of the United States · 1943
- Berry v. KuhlCourt of Appeals for the Seventh Circuit · 1949
- Houston Fearless Corporation v. Guy Teter, No. I.A. 25Court of Appeals for the Tenth Circuit · 1962
4 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Title Insurance and Trust Company v. United StatesDistrict Court, S.D. California · 1965
- Estate of Dumesnil v. CommissionerUnited States Tax Court · 1982
- Estate of James v. CommissionerUnited States Tax Court · 1963
- Estate of Schildkraut v. CommissionerUnited States Tax Court · 1965
- Estate of Zentmayer v. CommissionerUnited States Tax Court · 1963
1 more not listed; retrieve them via the Exa API.