Internal Revenue Service
Revenue Ruling

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 Rev. Rul. 54-48

1954-1 C.B. 24

Sec. 61

Full Text

Rev. Rul. 54-48

In Commissioner v. Ruth S. Clark et al. , 202 Fed.(2d) 94, the Court held, on the facts presented, that the income of the trust there involved was not taxable to the grantor under the 10-year short-term trust rule set forth in section 29.22(a)-21( c ) of Regulations 111 (now sec. 39.22(a)-21(c) of Regulations 118) the facts being that (1) the trust was created prior to promulgation of that section of the regulations, (2) the trust was extended prior to promulgation of such regulations so that its total term was 10 years, and (3) the beneficiary of the trust was a charitable corporation. The Internal Revenue Service will follow that decision in the disposition of other cases only if the issue and the facts in such cases are identical to those in the Clark case. Section 29.22(a)-21 of Regulations 111 was promulgated December 29, 1945. See T.D. 5488, C.B. 1946-1, 19.