Ross v. United States
United States Court of Appeals for the Fifth Circuit
348 F.2d 577 (1965)
- Written by Daniel Clark, JD
Facts
James and Nell Ross (plaintiffs) established trusts to benefit their minor grandchildren. The trust documents granted the trustees the discretion to manage the income of the trusts “to the same extent as if [the trustees] were the guardian of the beneficiary’s person.” The trustee of each trust was to distribute the corpus of the trust to its beneficiary on the beneficiary’s twenty-first birthday. The Rosses claimed the gift-tax exclusion on their contributions to the trusts. The Internal Revenue Service denied the exclusion claims. The Rosses then sued the government (defendant) in district court. The district court ruled in favor of the government, and the Rosses appealed.
Rule of Law
Issue
Holding and Reasoning (Wisdom, J.)
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