Legal Opinion

Estate of Williams v. Commissioner

United States Tax Court

Decided June 25, 1974No. Docket No. 6194-72Published

In his will decedent's uncle, Joseph L. Friedman, who died in 1913, established a trust for the benefit of his mother and his three sisters and their heirs. The trust was to continue in existence until 21 years after the death of the last of Friedman's sisters to die, which will be in 1975. The will provided that, at the expiration of the 21-year period, "then the estate in the hands of the trustee shall be divided, one-third to the heirs of each of my said sisters."

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In his will decedent's uncle, Joseph L. Friedman, who died in 1913, established a trust for the benefit of his mother and his three sisters and their heirs. The trust was to continue in existence until 21 years after the death of the last of Friedman's sisters to die, which will be in 1975. The will provided that, at the expiration of the 21-year period, "then the estate in the hands of the trustee shall be divided, one-third to the heirs of each of my said sisters." Decedent received one-half of his mother's one-third share of the income from the trust until his death in 1968. He was…

1Opinion of the Court

Estate of Clarence A. Williams, Deceased, William E. Nodine, Administrator, d.b.n. c.t.a., Petitioner v. Commissioner of Internal Revenue, Respondent

Estate of Williams v. Commissioner

Docket No. 6194-72

United States Tax Court

62 T.C. 400; 1974 U.S. Tax Ct. LEXIS 87; 62 T.C. No. 46;

June 25, 1974, Filed

Decision will be entered for the petitioner.

In his will decedent's uncle, Joseph L. Friedman, who died in 1913, established a trust for the benefit of his mother and his three sisters and their heirs. The trust was to continue in existence until 21 years after the death of the last of Friedman's…

2Cases cited12 opinions

  1. Commissioner v. Estate of BoschSupreme Court of the United States · 1967
  2. Aquilino v. United StatesSupreme Court of the United States · 1960
  3. Blair v. CommissionerSupreme Court of the United States · 1937
  4. Morgan v. CommissionerSupreme Court of the United States · 1940
  5. Earle v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1946

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