Missouri Revised Statutes

Mo. Rev. Stat. § 456.6 (2026)

Health savings account, trust may be created, when

✓ current as of May 2026
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  456.006.  Health savings account, trust may be created, when. — 1.  Where a trust or custodial account constitutes a health savings account, as defined under 26 U.S.C. Section 223(d)(1)*, a trust may be created by any of the following:

  (1)  A transfer of moneys to the trustee or custodian holding such trust or custodial account;

  (2)  The documentation of the creation of such trust or custodial account in the records of the trustee or custodian holding such trust or custodial account; or

  (3)  The execution of a trust or custodial agreement with respect to such trust or custodial account.

  2.  In any case, a trust or custodial account shall be deemed to have been established on the first day on which the individual who is the beneficiary of such trust or custodial account is an eligible individual, as defined under 26 U.S.C. Section 223(c)(1), in that calendar year in which such trust or custodial account is created in accordance with this section.

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(L. 2018 H.B. 1250)

*Section "223(c)(1)" appears in original rolls, which is an incorrect reference.

Notes of Decisions
Cited in 3 cases (1 in the last 5 years), 2015–2023 · leading case: Anthony Hoyt v. David Robertson (Mo. Ct. App. 2019).
Anthony Hoyt v. David Robertson (Mo. Ct. App. 2019). · cites it 24× “More specifically, Husband maintains that Wife was equitably estopped from amending the Trust by removing the provisions benefiting Husband in that Husband relied on the oral promise of those benefits as an inducement to sign the Deed conveying the Farm to the Trust.”
James Massey, Plaintiff-respondent v. Dearl Don Eugene Massey, Tr. of the Ina Wade Revocable Living Trust, & Betty Roderick, Gary E. Massey, Ina Lee Massey Kalina, Tammy Sue Massey Richardson, Keeli Hurst, Defendants-respondents, Shane Hurst (Mo. Ct. App. 2015). · cites it 2× “The Challenged Factual Proposition (Houston step one) Shane concedes that Ina had authority under the terms of her trust and section 456.6- 602.3(2) to amend her trust.”
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