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Revenue Ruling 2006-26

2006-22 I.R.B. 939 (2006)

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Revenue Ruling 2006-26

Internal Revenue Service
2006-22 I.R.B. 939 (2006)

Facts

A husband established an individual retirement account (IRA). At his death, his will created a marital trust to hold his assets. The trust was also named as the beneficiary of the IRA. The trust’s terms required the trustee to pay the husband’s wife all income generated by the trust principal during her lifetime in annual installments. The wife also had the right to annually compel the trustee to withdraw an amount equal to the IRA’s annual income and distribute it to her. The trust’s terms specified that when the wife died, the trust principal passed to the husband’s children. The executor of the husband’s estate wanted to treat both the trust and the IRA as qualified terminable-interest property (QTIP) to delay estate-tax liability until the wife’s death. Such treatment was possible only if the wife had a qualifying income interest for life in each. The Internal Revenue Service issued a revenue ruling to clarify the circumstances in which a surviving spouse has a qualifying income interest for life in a marital trust and an IRA held by the trust.

Rule of Law

Issue

Holding and Reasoning ()

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