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United States v. O'Malley
Unites States Supreme Court
383 U.S. 627 (1966)
Facts
Edward Fabrice created five irrevocable trusts and transferred property into them. Fabrice named himself as one of the trustees for all five trusts. As a trustee, Fabrice had complete discretion whether to distribute the incomes from the trusts to the beneficiaries (Fabrice’s wife and children) or to add the incomes to the trusts’ principals. After Fabrice’s death, the federal government (defendant) determined that the trusts’ original principals and all accumulated incomes were part of Fabrice’s gross estate because Fabrice had retained control over when the beneficiaries could possess and enjoy those properties. Fabrice’s estate (plaintiff) petitioned for a determination that neither the trusts’ original principals nor the accumulated incomes were part of the gross estate. The federal district court ruled that the trusts’ original principals were part of Fabrice’s gross estate but that the accumulated incomes were not. The appellate court affirmed the split ruling. The United States Supreme Court agreed to review the matter.
Rule of Law
Issue
Holding and Reasoning (White, J.)
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