Rippey v. Commissioner
United States Tax Court
The beneficiary of a testamentary trust agreed to reimburse the executors of the estate if they would pay a stipulated estate tax deficiency. Held, beneficiary's reimbursement payment pursuant to this agreement constituted the payment of Federal estate tax for which she could receive no deduction from her gross income as ordinary and necessary expense under section 23 (a) (2) of the 1939 Code.
1Opinion of the Court
OPINION.
Mulroney, Judge:
The respondent'determined a deficiency in income tax of petitioner for the taxable year 1947 in the sum of $28,833.12.
Petitioner, a resident of Denver, Colorado, filed her individual income tax return for the taxable year 1947 with the collector of internal revenue for the district of Colorado. In this return she claimed, among other deductions from gross income, an amount of $34,070.63, which the return described as “(payment made to meet estate tax deficiency and thus protect taxpayer’s income from Trust).” Disallowance by the Commissioner of this deduction led to…
2Cases cited3 opinions
- Beck v. CommissionerUnited States Tax Court · 1950
- Bache Trust v. CommissionerUnited States Tax Court · 1955
- Matthiessen v. United StatesUnited States Court of Claims · 1929
3Cited by6 opinions
- Uhlenbrock v. CommissionerUnited States Tax Court · 1977
- Findlay v. CommissionerUnited States Tax Court · 1962
- The L. B. Foster Company v. United StatesCourt of Appeals for the Third Circuit · 1957
- Findlay v. CommissionerUnited States Tax Court · 1962
- Rippey v. CommissionerUnited States Tax Court · 1956
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