Grasselli v. Commissioner
United States Tax Court
Petitioner was donee of a power of appointment under a trust created in 1932, of which she was not a trustee. Her children were cobeneficiaries. She was empowered to alter, amend, or terminate the trust and to cause distribution of corpus to herself or her appointees. The trustee paid income to the other beneficiaries from 1936 to 1940, inclusive.
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Petitioner was donee of a power of appointment under a trust created in 1932, of which she was not a trustee. Her children were cobeneficiaries. She was empowered to alter, amend, or terminate the trust and to cause distribution of corpus to herself or her appointees. The trustee paid income to the other beneficiaries from 1936 to 1940, inclusive. On July 30, 1941, petitioner in writing amended the trust by dividing the corpus into three parts, one of which was to go to each of the two children, she relinquishing all power over it and retaining power over the third fund, which power she…
1Opinion of the Court
Mabel F. Grasselli, Petitioner, v. Commissioner of Internal Revenue, Respondent
Grasselli v. Commissioner
Docket No. 7391
United States Tax Court
7 T.C. 255; 1946 U.S. Tax Ct. LEXIS 133;
June 28, 1946, Promulgated
Decision of no deficiency will be entered.
Petitioner was donee of a power of appointment under a trust created in 1932, of which she was not a trustee. Her children were cobeneficiaries. She was empowered to alter, amend, or terminate the trust and to cause distribution of corpus to herself or her appointees. The trustee paid income to the other beneficiaries from 1936 to 1940, inclusive.…
2Cases cited5 opinions
- Estate of Sanford v. CommissionerSupreme Court of the United States · 1939
- Burnet v. GuggenheimSupreme Court of the United States · 1933
- Du Pont v. CommissionerUnited States Tax Court · 1943
- Cerf v. CommissionerUnited States Tax Court · 1943
- Grasselli v. CommissionerUnited States Tax Court · 1946