26 USC § 651 - Deduction for trusts distributing current income only

---
identifier: "/us/usc/t26/s651"
source: "usc"
legal_status: "official_prima_facie"
title: "26 USC § 651 - Deduction for trusts distributing current income only"
title_number: 26
title_name: "INTERNAL REVENUE CODE"
section_number: "651"
section_name: "Deduction for trusts distributing current income only"
chapter_number: 1
chapter_name: "NORMAL TAXES AND SURTAXES"
subchapter_number: "J"
subchapter_name: "Estates, Trusts, Beneficiaries, and Decedents"
part_number: "I"
part_name: "ESTATES, TRUSTS, AND BENEFICIARIES"
positive_law: false
currency: "119-84"
last_updated: "2026-04-17"
format_version: "1.1.0"
generator: "[email protected]"
source_credit: "(Aug. 16, 1954, ch. 736, 68A Stat. 219.)"
---


# § 651. Deduction for trusts distributing current income only

**(a)** **Deduction** In the case of any trust the terms of which—

there shall be allowed as a deduction in computing the taxable income of the trust the amount of the income for the taxable year which is required to be distributed currently. This section shall not apply in any taxable year in which the trust distributes amounts other than amounts of income described in paragraph (1).

**(1)** provide that all of its income is required to be distributed currently, and

**(2)** do not provide that any amounts are to be paid, permanently set aside, or used for the purposes specified in section 642(c) (relating to deduction for charitable, etc., purposes),

**(b)** **Limitation on deduction** If the amount of income required to be distributed currently exceeds the distributable net income of the trust for the taxable year, the deduction shall be limited to the amount of the distributable net income. For this purpose, the computation of distributable net income shall not include items of income which are not included in the gross income of the trust and the deductions allocable thereto.

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**Source Credit**: (Aug. 16, 1954, ch. 736, 68A Stat. 219.)