Wilson
United States Tax Court
P was trustee of a trust in which she was the sole income beneficiary and possessed a general power of appointment. P, as trustee, transferred real estate owned by the trust to her three children and received in return an installment note which was due at the earlier of 120 days after demand for payment or 15 years after the date of the note. If P died prior to the due date, the note self-canceled.
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P was trustee of a trust in which she was the sole income beneficiary and possessed a general power of appointment. P, as trustee, transferred real estate owned by the trust to her three children and received in return an installment note which was due at the earlier of 120 days after demand for payment or 15 years after the date of the note. If P died prior to the due date, the note self-canceled. Every year an amount equal to 6 percent of the unpaid balance was added to the balance of the note. The note was secured by a deed of trust on the property. P and her children expected the note to…
1Opinion of the Court
CATHERINE L. WILSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Wilson
Docket No. 10948-90
United States Tax Court
T.C. Memo 1992-480; 1992 Tax Ct. Memo LEXIS 501; 64 T.C.M. (CCH) 583;
August 24, 1992, Filed
Decision will be entered for petitioner.
P was trustee of a trust in which she was the sole income beneficiary and possessed a general power of appointment. P, as trustee, transferred real estate owned by the trust to her three children and received in return an installment note which was due at the earlier of 120 days after demand for payment or 15 years after the date of the…
2Cases cited5 opinions
- Story v. CommissionerUnited States Tax Court · 1962
- Estate of Kelley v. CommissionerUnited States Tax Court · 1974
- Haygood v. CommissionerUnited States Tax Court · 1964
- Laughinghouse v. Comm'rUnited States Tax Court · 1983
- Davies v. CommissionerUnited States Tax Court · 1963
3Cited by3 opinions
- Estate of Lydia G. Maxwell, Deceased First National Bank of Long Island Victor C. McCuaig Jr., Executors v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1993
- Estate of Musgrove v. United StatesUnited States Court of Federal Claims · 1995
- Estate of Lydia G. Maxwell, Deceased First National Bank of Long Island Victor C. McCuaig Jr., Executors v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1993