Legal Opinion

Linde v. Commissioner

United States Tax Court

Decided October 4, 1951No. Docket No. 24517Published

In the year 1944, the estate of petitioner's deceased husband received from cooperatives proceeds from the liquidation of certain of their "wine pools", in which decedent had held interests, and payment of certain sums of money due and owing the decedent on the date of his death.

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In the year 1944, the estate of petitioner's deceased husband received from cooperatives proceeds from the liquidation of certain of their "wine pools", in which decedent had held interests, and payment of certain sums of money due and owing the decedent on the date of his death. The administration of the estate was terminated in 1944. In the same year these amounts were distributed to the petitioner as sole legatee under the decedent's will, and in the year 1945 the cooperatives paid to the petitioner other proceeds from the 1945 liquidation of certain of the wine pools. The total proceeds…

1Opinion of the Court

Rose J. Linde, Petitioner, v. Commissioner of Internal Revenue, Respondent

Linde v. Commissioner

Docket No. 24517

United States Tax Court

17 T.C. 584; 1951 U.S. Tax Ct. LEXIS 69;

October 4, 1951, Promulgated

Decision will be entered under Rule 50.

In the year 1944, the estate of petitioner's deceased husband received from cooperatives proceeds from the liquidation of certain of their "wine pools", in which decedent had held interests, and payment of certain sums of money due and owing the decedent on the date of his death. The administration of the estate was terminated in 1944. In the same year…

2Cases cited6 opinions

  1. Bogardus v. Santa Ana Walnut Growers Assn.California Court of Appeal · 1940
  2. San Joaquin Valley Poultry Producers' Ass'n v. CommissionerCourt of Appeals for the Ninth Circuit · 1943
  3. Linde v. CommissionerUnited States Tax Court · 1951
  4. Estate of Huesman v. CommissionerUnited States Tax Court · 1951
  5. California & Hawaiian Sugar Refining Corp. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1947

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