Court of Appeals for the Ninth Circuit January 21, 1997, 95-70501 (Leila G. Newhall Unitrust, Wells Fargo Bank, Trustee v. Commissioner of Internal Revenue Service)

WILLIAM W SCHWARZER, Senior District Judge:

We, are called upon to decide whether a charitable remainder unitrust within 26 U.S.C. § 664(d)(2) that receives unrelated business taxable income from publicly traded limited partnerships is subject to tax on its entire income, including income otherwise exempt from tax.

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FACTUAL BACKGROUND

The Leila G.