Braun v. Commissioner

T.C. Memo 1984-285, 48 T.C.M. (CCH) 210 (1984)

From our private database of 46,100+ case briefs, written and edited by humans—never with AI.

Braun v. Commissioner

United States Tax Court
T.C. Memo 1984-285, 48 T.C.M. (CCH) 210 (1984)

JC

Facts

Dr. Frederick Braun (plaintiff) and his wife set up a pair of trusts, each for the benefit of three of their children. Braun, his wife, and a friend were the trustees. Each trust called for distribution of the net income to its beneficiaries. Income from the trusts was used to fund college tuition, room, and board for the children who had reached age 18. Other trust income was used to fund private high school for two beneficiaries, one of whom later turned 18 and had his share of the income applied to college, and the other of whom was under 18 for the period in question and thus remained in high school. If trust income was applied for support or maintenance of a beneficiary whom the grantor was obligated to support, then it was taxable income to the grantor. Obligation was determined under state law. Braun contended that he had no obligation to pay college tuition, room, and board for his adult children or to pay for private school tuition for his minor child. The government (defendant) disagreed, arguing that the trust income should be taxable to Braun. In a prior case that had sought to provide clarity to findings in regard to the necessaries doctrine, the New Jersey Supreme Court found that education was to be considered flexibly and based upon relevant circumstances.

Rule of Law

Issue

Holding and Reasoning (Whitaker, J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 748,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.

    Unlock this case briefRead our student testimonials
  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.

    Learn about our approachRead more about Quimbee

Here's why 748,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 46,100 briefs, keyed to 987 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Access this case brief for FREE

With a 7-day free trial membership
Here's why 748,000 law students have relied on our case briefs:
  • Reliable - written by law professors and practitioners, not other law students
  • The right length and amount of information - includes the facts, issue, rule of law, holding and reasoning, and any concurrences and dissents
  • Access in your class - works on your mobile and tablet
  • 46,100 briefs - keyed to 987 casebooks
  • Uniform format for every case brief
  • Written in plain English - not in legalese and not just repeating the court's language
  • Massive library of related video lessons - and practice questions
  • Top-notch customer support

Access this case brief for FREE

With a 7-day free trial membership