Legal Opinion

Clark v. Commissioner

United States Tax Court

Decided February 20, 1952No. Docket Nos. 29011, 29081Published

Petitioners are settlors of irrevocable trusts which, as extended on December 1, 1942, were to run in each case for a period of at least 9 years. The income of each trust was to be paid to a charitable corporation which was organized under the laws of Illinois, not for profit.

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Petitioners are settlors of irrevocable trusts which, as extended on December 1, 1942, were to run in each case for a period of at least 9 years. The income of each trust was to be paid to a charitable corporation which was organized under the laws of Illinois, not for profit. Petitioners retained no power of control over either the corpus or the income of the trusts, and none of the income of either trust was to be used for the benefit of any member of the family of petitioners. Respondent determined that part of the income of the trusts in the year 1946 was taxable to petitioners under…

1Opinion of the Court

Ruth S. Clark, Petitioner, v. Commissioner of Internal Revenue, Respondent. Hazel S. Rutherford, Petitioner, v. Commissioner of Internal Revenue, Respondent

Clark v. Commissioner

Docket Nos. 29011, 29081

United States Tax Court

17 T.C. 1357; 1952 U.S. Tax Ct. LEXIS 270;

February 20, 1952, Promulgated

Decision will be entered under Rule 50 in Docket No. 29011.

Decision will be entered for the petitioner in Docket No. 29081.

Petitioners are settlors of irrevocable trusts which, as extended on December 1, 1942, were to run in each case for a period of at least 9 years. The income of each trust was to be…

Also in this document: Dissent · Turner; Dissent · Raum.

2Cases cited7 opinions

  1. Helvering v. CliffordSupreme Court of the United States · 1940
  2. United States v. PierceCourt of Appeals for the Eighth Circuit · 1943
  3. Commissioner of Internal Revenue v. ChamberlainCourt of Appeals for the Second Circuit · 1941
  4. Helvering v. AchelisCourt of Appeals for the Second Circuit · 1940
  5. Commissioner of Internal Revenue v. LamontCourt of Appeals for the Second Circuit · 1942

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