Estate of Draper v. Commissioner

1988 T.C. Memo. 201, 55 T.C.M. 797, 1988 Tax Ct. Memo LEXIS 228
CourtUnited States Tax Court
DecidedMay 5, 1988
DocketDocket No. 48263-86.
StatusUnpublished

This text of 1988 T.C. Memo. 201 (Estate of Draper v. Commissioner) is published on Counsel Stack Legal Research, covering United States Tax Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Estate of Draper v. Commissioner, 1988 T.C. Memo. 201, 55 T.C.M. 797, 1988 Tax Ct. Memo LEXIS 228 (tax 1988).

Opinion

ESTATE OF HARRY K. DRAPER, DECEASED, BARBARA K. DRAPER EXECUTRIX, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Estate of Draper v. Commissioner
Docket No. 48263-86.
United States Tax Court
T.C. Memo 1988-201; 1988 Tax Ct. Memo LEXIS 228; 55 T.C.M. (CCH) 797; T.C.M. (RIA) 88201;
May 5, 1988.
Arthur O. Gormley, Jr., for the petitioner.
David N. Brodsky and Randall P. Andreozzi, for the respondent.

COHEN

MEMORANDUM FINDINGS OF FACT AND OPINION

COHEN, Judge: Respondent determined a deficiency of $ 101,239.97 in petitioner's Federal estate tax and an addition to tax of $ 25,309.99 under section 6651(a). 1 After concessions by petitioner, the issues for decision are (1) whether decedent gave his surviving spouse under a trust agreement a power of appointment within the meaning of section 2056(b)(5) so as to qualify the trust*230 property for the marital deduction, and (2) whether petitioner's failure to file its estate tax return when due was attributable to reasonable cause.

FINDINGS OF FACT

Some of the facts have been stipulated, and the facts set forth in the stipulation are incorporated in our findings by this reference.

Harry K. Draper (decedent) died December 2, 1982, a resident of Milford, New Hampshire. Decedent was survived by his wife, Barbara K. Draper (Mrs. Draper), now Barbara Ryan, and two children, Richard Draper (R. Draper) and David Draper. Mrs. Draper was named executrix of the estate.

On October 23, 1981, decedent executed his last will and a trust agreement. In his will, decedent bequeathed all of his tangible personal property to Mrs. Draper; the remainder of his probate estate was to pourover to the trust.

The relevant portions of decedent's trust agreement are as follows:

ARTICLE I

Harry K. Draper shall be the sole TRUSTEE of this Trust Agreement, and Barbara K. Draper and Richard Draper shall become Successor Co-TRUSTEES if any of the following*231 events occur:

(a) The death of Harry K. Draper.

* * *

ARTICLE III

Upon the death of the SETTLOR, TRUSTEES shall use their best efforts to collect the proceeds of any insurance policies payable to the trust, * * * and shall hold the same and any other property which may have been added to the trust estates created hereby by gift, devise or bequest (all of which is sometimes referred to as the Trust Property) in accordance with the following:

A. TRUSTEES shall pay to or for the benefit of SETTLOR'S wife, Barbara K. Draper, all of the net income and so much of the principle as TRUSTEES in their sole descretion deem wise and proper for her maintenance, support, comfort, enjoyment, medical bills and hospital bills. In the event of any incapacity on the part of SETTLOR'S said wife, said Richard Draper shall have the power to exercise such discretion alone and independently.

B. Upon the decease of said Barbara K. Draper, this trust shall terminate and the residue of the principal and accumulated income shall be distributed in equal shares to the SETTLOR'S sons, Richard Draper and David Draper.

The trust agreement also authorized the resignation of any trustee.

Mrs. Draper*232 was inexperienced in estate tax law and expected and relied upon decedent's attorney to prepare petitioner's estate tax return. The filing due date for the return was September 2, 1983. The return was filed, however, on April 13, 1984, over 7 months later. The return treated all property held by the trust valued at $ 565,060.32 on the date of decedent's death, as if it qualified for the marital deduction.

In his notice of deficiency, respondent disallowed petitioner's marital deduction to the extent of the value of the trust property and determined an addition to the tax for late filing.

OPINION

1. Marital Deduction

Section 2056(a) allows a Federal estate tax "marital deduction" from a decedent's gross estate for the value of property interests form the benefits of the marital deduction provided by section 2056(a). Section 2056(b)(5) 2 provides and exception to section 2056(b)(1) with regard to life estates with qualifies powers of appointment in the surviving spouse. Section 2056(b)(5) requires that the surviving spouse have the power to appoint the property in favor of herself (as, for example, and unlimited power to invade), or her estate, or both and that the power*233 be "exercisable by such spouse alone and in all events."

*234 The parties do not dispute that Mrs. Draper lacked a power to appoint the property to her estate, for the trust agreement specifically named Richard Draper and David Draper as vested remaindermen to take equally upon Mrs. Draper's death. Rather, their dispute concerns whether Mrs. Draper held a power to invade the trust corpus, alone and in all events, as required by section 2056(b)(5). We hold that she did not.

A power to appoint is not considered to be exercisable by a surviving spouse alone and in all events if the exercise of the power by the surviving spouse requires the joinder or consent of any other person. Section 20.2056(b)-5(g)(3), Estate Tax Regs. In virtually all jurisdictions, co-trustees of a private trust must concur in the exercise of powers conferred upon them, unless the terms of the trust provide otherwise. Scott, Law of Trusts, sec. 194 (3d ed. 1967); 76 Am. Jur. 2d sec. 299 (1975). See also 1 Restatement, Trusts 2d, sec. 194 (1959). New Hampshire law is consistent with this general rule. See

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1988 T.C. Memo. 201, 55 T.C.M. 797, 1988 Tax Ct. Memo LEXIS 228, Counsel Stack Legal Research, https://law.counselstack.com/opinion/estate-of-draper-v-commissioner-tax-1988.