Estate of Humbert v. Commissioner
United States Tax Court
On Sept. 5, 1969, decedents made inter vivos transfers to separate, identical trusts, reserving the right to receive specified monthly payments during their lives. After their deaths, "part or all of the principal" was to be paid to Martha Irene Humbert "or applied for her benefit but only in such amounts as the Trustee deems necessary in its discretion." On Martha's death, the principal of the two trusts was to be paid to designated charities.
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On Sept. 5, 1969, decedents made inter vivos transfers to separate, identical trusts, reserving the right to receive specified monthly payments during their lives. After their deaths, "part or all of the principal" was to be paid to Martha Irene Humbert "or applied for her benefit but only in such amounts as the Trustee deems necessary in its discretion." On Martha's death, the principal of the two trusts was to be paid to designated charities. On Nov. 3, 1969, decedents executed wills leaving the residue of their respective estates to their separate trusts. Both of the decedents died in…
1Opinion of the Court
Estate of Virginia I. Humbert, Deceased, Philip J. O'Connell and F. King Tiedeman, Coexecutors, Petitioner v. Commissioner of Internal Revenue, Respondent; Estate of Ralph H. Humbert, Deceased, Philip J. O'Connell and F. King Tiedeman, Coexecutors, Petitioner v. Commissioner of Internal Revenue, Respondent
Estate of Humbert v. Commissioner
Docket Nos. 7147-75, 7148-75
United States Tax Court
70 T.C. 542; 1978 U.S. Tax Ct. LEXIS 89;
July 18, 1978, Filed
Decisions will be entered for the respondent.
On Sept. 5, 1969, decedents made inter vivos transfers to separate, identical trusts, reserving the…
2Cases cited13 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Ithaca Trust Co. v. United StatesSupreme Court of the United States · 1929
- Merchants Nat. Bank of Boston v. CommissionerSupreme Court of the United States · 1943
- Taylor v. CommissionerUnited States Tax Court · 1977
- Newton Trust Co. v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1947
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