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Revenue Ruling 79-63
Internal Revenue Service
1979-1 C.B. 302 (1979)
- Written by Eric Miller, JD
Facts
A decedent’s spouse created a trust providing for payment of income to the decedent for life and making the remainder payable to the decedent’s children. The trust gave the decedent the right to distribute any part of the trust property to anyone, though this required the consent of C, one of the decedent’s children. The Internal Revenue Service considered whether the decedent’s power of appointment was jointly held with C, in which case the decedent’s interest in the trust property would not be treated as a general power of appointment includable in the gross estate.
Rule of Law
Issue
Holding and Reasoning ()
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