Farmers Loan & Trust Co. v. Commissioner
United States Board of Tax Appeals
The taxpayer as administrator made return and paid tax on the transfer of the estate of Nathaniel Whitman in the year 1919 and claims the right to deduct the said tax from its return of income for the estate for the period in which the tax was paid. Held, that the New York State transfer tax was a proper deduction from income of an estate and that said tax is not deductible by the beneficiaries thereof.
1Opinion of the Court
*98OPINION.
James: The question involved in this appeal requires the construction of sections 210, 211, 214 (a) (3) and 219 (a) and (b) of the Revenue Act of 1918, and article 10 of the Tax Law of the State of New York, being the article dealing with the subject of taxable transfers.
Sections 210, 211, and 219 of the Revenue Act of 1918 imposed taxes upon individuals, estates and trusts at rates therein named. Section 214 of that Act provides in part as follows :
Sec. 214. (a) That in computing net income there shall be allowed as deductions :
* * * * * * *(3) Taxes paid or accrued within the…
2Cases cited18 opinions
- Knowlton v. MooreSupreme Court of the United States · 1900
- New York Trust Co. v. EisnerSupreme Court of the United States · 1921
- Magoun v. Illinois Trust & Savings BankSupreme Court of the United States · 1898
- South Carolina v. United StatesSupreme Court of the United States · 1905
- Young Men's Christian Assn. of Columbus v. DavisSupreme Court of the United States · 1924
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3Cited by2 opinions
- Farmers Loan & Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1925
- Munson v. CommissionerUnited States Board of Tax Appeals · 1925