Estate of Crafts v. Commissioner
United States Tax Court
Decedent possessed an inter vivos power of appointment over property held in trust; said property was includable in her gross estate under sec. 2041, I.R.C. 1954. The trust, which had been established under the will of the decedent's predeceased husband, provided for income interests in favor of various individuals as well as a 40-percent income interest for the benefit of the Webb Institute (Webb), a charitable organization.
Read the full summary
Decedent possessed an inter vivos power of appointment over property held in trust; said property was includable in her gross estate under sec. 2041, I.R.C. 1954. The trust, which had been established under the will of the decedent's predeceased husband, provided for income interests in favor of various individuals as well as a 40-percent income interest for the benefit of the Webb Institute (Webb), a charitable organization. The remainder interest was divided between Webb and another charity in the respective proportions of 75 and 25 percent. The estate's representative requested a ruling…
1Opinion of the Court
OPINION
Nims, Judge:
Respondent determined a deficiency in the Federal estate tax of the Estate of Nancy F. Crafts, deceased, William A. Dicus, personal representative (the estate), in the amount of $64,419.
Concessions having been made, the issues for decision are: (1) Whether a split-interest charitable remainder trust established by the will of decedent’s husband and includable in the estate by virtue of decedent’s general power of appointment is subject to the provisions of section 2055(e);1 (2) if section 2055(e) is applicable, whether a postmortem division of the trust property can qualify…
2Cases cited14 opinions
- Lyeth v. HoeySupreme Court of the United States · 1938
- National Muffler Dealers Assn., Inc. v. United StatesSupreme Court of the United States · 1979
- Helvering v. BlissSupreme Court of the United States · 1934
- Helvering v. ReynoldsSupreme Court of the United States · 1941
- Groman v. CommissionerSupreme Court of the United States · 1937
9 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Shriners Hospitals for Crippled Children, as Transferee and Successor in Interest to the Estate of Ernest C. Hudson v. The United StatesCourt of Appeals for the Federal Circuit · 1988
- Oxford Orphanage, Inc. v. United StatesCourt of Appeals for the Fourth Circuit · 1985
- Wells Fargo Bank v. United StatesCourt of Appeals for the Ninth Circuit · 1993
- Estate of Hall v. CommissionerUnited States Tax Court · 1989
- Oetting v. United StatesDistrict Court, E.D. Missouri · 1982
5 more not listed; retrieve them via the Exa API.