Schoellkopf v. Commissioner
United States Board of Tax Appeals
A private corporation, doing business in the State of Texas, and owning a varied assortment of obligations of subdivisions of the States of Texas and New Mexico, created a trust and transferred the municipal obligations to it, the corporation thereupon issuing trust certificates secured by the obligations in trust, the interest upon the trust certificates, except in certain instances, being payable by the trustee out of interest collected on the obligations.
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A private corporation, doing business in the State of Texas, and owning a varied assortment of obligations of subdivisions of the States of Texas and New Mexico, created a trust and transferred the municipal obligations to it, the corporation thereupon issuing trust certificates secured by the obligations in trust, the interest upon the trust certificates, except in certain instances, being payable by the trustee out of interest collected on the obligations. Held, the interest paid to the holders of the trust certificates is to be included in gross income, and is not free from tax as interest…
1Opinion of the Court
BESS SCHOELLKOPF, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
L. R. MUNGER AND J. FRED SCHOELLKOPF, EXECUTORS OF THE ESTATE OF LAURA D. WILSON, DECEASED, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Schoellkopf v. Commissioner
Docket Nos. 71974, 71975.
United States Board of Tax Appeals
32 B.T.A. 88; 1935 BTA LEXIS 999;
February 19, 1935, Promulgated
A private corporation, doing business in the State of Texas, and owning a varied assortment of obligations of subdivisions of the States of Texas and New Mexico, created a trust and transferred the municipal obligations…
2Cases cited2 opinions
- Carson Estate Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Schoellkopf v. CommissionerUnited States Board of Tax Appeals · 1935