Stern v. Commissioner

14 B.T.A. 444, 1928 BTA LEXIS 2973
United States Board of Tax Appeals·Decided November 27, 1928·No. Docket Nos. 16692, 18862.·Published·Cited by 1 cases

Opinion

[454]*454OPINION.

Van Fossan:

In these proceedings each of the petitioners seeks to deduct from gross income a proportionate part of losses alleged to have been sustained in the taxable year on two pieces of real property. It is contended that each petitioner was the absolute, legal and equitable, owner of a three-fortieths interest in both properties during the taxable year and at the time of the losses, such interests, it is claimed, having been acquired in the preceding year under the wills of Lewis Seasongood, deceased, and Emma Seasongood, deceased, father and mother, respectively, of the petitioners. The properties in question were originally owned jointly or in common by Lewis Seasongood and Jacob Seasongood, father of Emma Season-good, and such interest as Emma Seasongood had came to her under the will of her father. The respondent refused to allow the deductions upon the ground that both properties were still held in trust under the wills of the original owners during the taxable year and at the time of the losses, and that any losses sustained are deductible by the estates and not by the individual beneficiaries thereof.

The controlling question before us is whether or not the trusts created as to these properties by the wills of Jacob, Lewis and Emma Seasongood had terminated at or before the taxable year, and the legal title, as well as the equitable and beneficial title, of the petitioners to their respective interests in the properties had vested in possession at that time and at the dates of the losses. If the trusts had not terminated on or before the dates of the losses, and if the legal title to these properties at that time was still held by the trustees, or in trust by the executors, of the estates jointly or in common, and had not then, or prior thereto, vested in the petitioners and other beneficiaries, any losses sustained on the properties can not be deducted in any amount by the petitioners from their individual gross incomes. In the latter event such losses are deductible, if at all, by the respective estates in their proper proportion in computing the net income of the estates, and are not deductible by the petitioners, in proportionate shares, as beneficiaries of the estates. See section 219(b) of the Revenue Act of 1918; Louise P. V. Whitcomb et al., 4 B. T. A. 80; aff'd. D. C. App., 25 Fed. (2d) 528; Arthur H. Fleming, et al., 6 B. T. A. 900; George D. Widener, et al., 8 B. T. A. 651; and Baltzell v. Mitchell, 3 Fed. (2d) 428.

That Jacob, Lewis, and Emma Seasongood devised their respective interests in the properties in trust is not questioned nor is the validity of the several trusts attacked. The petitioners contend that [455]*455the trusts had terminated and absolute title to their-respective shares in these properties had vested in them at or before the time the alleged losses were sustained. It becomes necessary, therefore, to examine the wills of these testators and the applicable law to determine the title or estate vested in their trustees, the duration of the trust, and the nature of the estate in these properties held by petitioners.

The title or estate acquired by trustees in trust property is fixed by the requirements of the trust (see Young v. Bradley, 101 U. S. 782-787) and is coextensive with the powers conferred and the duties imposed. If a legal estate in fee be necessary to the proper execution of the trust, as where the trustee is empowered to sell property and reinvest the proceeds or income, or is directed to distribute and convey the property to the beneficiaries, such an estate will vest in the trustee. See McCormick v. Provident, etc. Ins. Co., 249 Fed. 141. The legal title having vested in the trustee, it can not be divested without a conveyance by him or by order of court. McArthur v. Scott, 113 U. S. 340. Generally, in the absence of a provision in the will or other instrument requiring the trustee to convey the legal title will vest by operation of law in the beneficiaries immediately upon the termination of the trust. The trust will not terminate, however, until the expiration of the time limited for its duration and the purposes of the trust have been performed or have failed. In some cases where the trust has been completely executed, it may be terminated prior to the expiration of the time prescribed for its existence by order of court"or by agreement between all parties beneficially interested.

The direction in a will that the trustee shall divide, distribute and convey trust property to the beneficiaries upon the expiration of the trust period is an imperative duty of the trustee and an express purpose of the trust, just as the instruction to pay the income of the estate to designated persons and to pay annuities are duties and purposes of the trust. See Fitchie v. Brown, 211 U. S. 321. This duty is one imposed upon the trustee and is to be discharged by him in the exercise of powers conferred by the will. In such cases, the trust will continue and the legal title will remain in the trustee until he divides, distributes and conveys the estate to the beneficiaries, notwithstanding the will directs that the division, distribution and conveyance be made at or within a certain time. So long as the trust continues and the legal title remains in the trustee, the beneficiaries of the estate have only an equitable title or interest therein. They can have no legal title, or right of possession, to any specific part of the trust property, real or personal. Potter v. Couch, 141 U. S. 296. See also McArthur v. Scott, supra.

[456]*456Although the duty of a trustee to convey the estate to the beneficiaries arises when the trust has terminated either by the expiration of time and the complete execution of the purposes thereof, or by the happening of the contingency upon which t'he conveyance is to be made, a conveyance will be presumed only in the absence of evidence to the contrary. And where it appears as a fact that no conveyance of the estate was ever made by the trustee, the legal title remains in him. See Lincoln v. French, 105 U. S. 614-616. A valid trust once established is presumed to continue and the burden of proof is upon him who denies that it longer exists. See Seymour v. Freer, 8 Wall. 202.

Jacob Seasongood devised and bequeathed his residuary estate to executors in trust for five of his children, of whom Emma Seasongood was one, until such time as it might become necessary, or his executors should deem it most practicable and advisable to make partition of the same, the income therefrom to be paid in equal shares to said five children. He further directed that “ should partition of my Estate be made as provided for, then and in that case, * * * the same (shall) be made by the mutual consent of my said executors, and without the intervention of any court.” To that end he authorized the executors, in their discretion, to sell and dispose of any of his estate, real or personal, and to purchase the interest of any person or persons with whom he might own realty in common.

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Stern v. Commissioner, 14 B.T.A. 444, 1928 BTA LEXIS 2973 (bta 1928).

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Stern v. Commissioner
14 B.T.A. 444 (Board of Tax Appeals, 1928)