Legal Opinion

Mellon v. Commissioner

United States Tax Court

Decided August 5, 1948No. Docket Nos. 13813, 15145, 15146, 15147Published

Trustor provided for payment of annuities to his 4 children as principal beneficiaries, and for division of the excess trust income into as many parts as the trustor had living grandchildren (or issue of grandchildren per stirpes) and that the income might be paid to the guardian of any minor beneficiary as the guardian might deem necessary for maintenance, education, and support of the minor beneficiary (or the trustees themselves might so apply the income), any unexpended…

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Trustor provided for payment of annuities to his 4 children as principal beneficiaries, and for division of the excess trust income into as many parts as the trustor had living grandchildren (or issue of grandchildren per stirpes) and that the income might be paid to the guardian of any minor beneficiary as the guardian might deem necessary for maintenance, education, and support of the minor beneficiary (or the trustees themselves might so apply the income), any unexpended income to be retained and invested until the minor became 21, then paid to him. In the taxable year the 12 secondary…

1Opinion of the Court

William L. Mellon, Jr. and Mellon National Bank and Trust Company (Successor by Merger and Consolidation to the Union Trust Company of Pittsburgh), Trustees under Deed of Trust of William L. Mellon Dated November 17, 1941, for William L. Mellon, Jr. and Others, Petitioner, et al. 1 v. Commissioner of Internal Revenue, Respondent

Mellon v. Commissioner

Docket Nos. 13813, 15145, 15146, 15147

United States Tax Court

11 T.C. 135; 1948 U.S. Tax Ct. LEXIS 112;

August 5, 1948, Promulgated

Decisions will be entered for the respondent.

Trustor provided for payment of annuities to his 4 children as principal…

2Cases cited2 opinions

  1. Huber's AppealSupreme Court of Pennsylvania · 1876
  2. Mellon v. CommissionerUnited States Tax Court · 1948

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