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Lober v. United States

346 U.S. 335 (1953)

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Lober v. United States

United States Supreme Court

346 U.S. 335 (1953)

Facts

Morris Lober created an irrevocable trust for each of his three children and appointed himself as trustee. Under the trust documents, Lober had full management power over the trusts’ assets until a child reached the age of 21, when he or she would receive any accumulated income in his or her respective trust. When a child reached age 25, Lober would be compelled to distribute the trust principal to the child. Lober also had the power to, at any time, distribute all or a portion of a given trust’s principal to its beneficiary, which would terminate that trust. Lober died while still trustee of the three trusts. The Internal Revenue Service (IRS) (defendant) determined that the trust property was includable in Lober’s gross estate. The executors of Lober’s estate (plaintiffs) disagreed. The estate paid the disputed liability and sued for a refund. The court of appeals found in favor of the IRS, and the executors of Lober’s estate appealed.

Rule of Law

Issue

Holding and Reasoning (Black, J.)

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