---
kind: "section"
citation: "26 U.S.C. § 651"
title: "26"
title_heading: "Internal Revenue Code"
number: "651"
heading: "Deduction for trusts distributing current income only"
release: "119-102"
url: "https://uscodex.org/usc/26/651"
units:
  - "Subtitle A — Income Taxes"
  - "Chapter 1 — Normal Taxes and Surtaxes"
  - "Subchapter J — Estates, Trusts, Beneficiaries, and Decedents"
  - "Part I — Estates, Trusts, and Beneficiaries"
  - "Subpart B — Trusts Which Distribute Current Income Only"
---

# §651. Deduction for trusts distributing current income only

- (a) **Deduction—** In the case of any trust the terms of which—
  - (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)](/usc/26/642.md?p=c) (relating to deduction for charitable, etc., purposes),

  there shall be allowed as a deduction in computing the [taxable income](/usc/26/63.md?p=b) of the trust the amount of the income for the [taxable year](/usc/26/441.md?p=b) which is required to be distributed currently. This section shall not apply in any [taxable year](/usc/26/441.md?p=b) in which the trust distributes amounts other than amounts of income described in [paragraph (1)](#a-1).

- (b) **Limitation on deduction—** If the amount of income required to be distributed currently exceeds the [distributable net income](/usc/26/643.md?p=a) of the trust for the [taxable year](/usc/26/441.md?p=b), the deduction shall be limited to the amount of the [distributable net income](/usc/26/643.md?p=a). For this purpose, the computation of [distributable net income](/usc/26/643.md?p=a) shall not include items of income which are not included in the gross income of the trust and the deductions allocable thereto.

## Source credit

(Aug. 16, 1954, ch. 736, 68A Stat. 219.)