Estate of Williams v. Commissioner
United States Tax Court
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
Deennen, Judge:
Kespondent determined a deficiency in Federal estate tax for the Estate of Clarence A. Williams in the amount of $115,821.54. The issues before the Court are whether, at the time of his death, Clarence A. Williams had a vested interest in either (1) a portion of the corpus of a testamentary trust established by his uncle or (2) the income from a portion of the corpus of the trust, which is includable in his gross estate under section 2038,1.K.C. 1954.
FINDINGS OF FACT
The facts have been fully stipulated by the parties and are found accordingly.
Petitioner is the Estate of…
2Cases cited11 opinions
- Commissioner v. Estate of BoschSupreme Court of the United States · 1967
- Aquilino v. United StatesSupreme Court of the United States · 1960
- Blair v. CommissionerSupreme Court of the United States · 1937
- Morgan v. CommissionerSupreme Court of the United States · 1940
- Earle v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1946
6 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Johnson v. CommissionerUnited States Tax Court · 1979
- Estate of Williams v. CommissionerUnited States Tax Court · 1974
- Hilton v. CommissionerUnited States Tax Court · 1990
- Jensen v. CommissionerUnited States Tax Court · 1979
- Johnson v. CommissionerUnited States Tax Court · 1979
1 more not listed; retrieve them via the Exa API.